Landsbanki Íslands hf
Summary of its Conflicts of Interest Policy
Landsbanki Íslands hf (‘Landsbanki’) is required to take all reasonable steps to identify conflicts of interest between: (1) Landsbanki, including its employees and controllers, and a client of theirs; or (2) one client of Landsbanki and another client of Landsbanki. Where Landsbanki owes a duty to such clients, it must maintain and operate arrangements to prevent any conflict from giving rise to a material risk of detriment to its clients. Landsbanki must also disclose the general nature of potential conflicts of interest to their clients and provide a summary of their conflicts of interest policy to retail clients. This document may form part of such disclosure and policy and should be provided to all clients of Landsbanki.
Potential Conflicts of Interest
Landsbanki is involved in investment banking activities including corporate finance and capital markets activities, corporate broking, trading and issuing research. It acts for companies that are seeking to raise money, and for investors in those companies. As a result the following conflicts may exist:
- Landsbanki may act for different clients with the same interests: for example, two investors attempting to acquire the same scarce asset; or different companies interested in acquiring a controlling stake in third company. Where we consider there may be a material detriment we may disclose the nature of this conflict, or decline to act. Where there is a scarcity in a security, we will allocate it in accordance with a policy requiring us to take into account objective criteria when deciding how to allot the assets. Where we are acting for an issuer, and there is an excess of demand for an issue, our policy takes into account the views of the issuer in deciding how it wants to allot the issue.
- Landsbanki may own shares in a company in circumstances where Landsbanki is providing corporate finance advice to that company; or advising other clients on investing in that company; or dealing in the shares of that company with other clients. Where this is the case, it is likely that the information on (for example) our corporate finance activities will not be known by any Landsbanki employee with responsibility for managing our holding in that company.
- Landsbanki may act as corporate broker to a company, and also trade in its securities with its investor clients. Where this is the case, corporate finance employees acting for the company will owe their duties to the company, and the sales and trading team will owe their duties to their investor clients.
- Landsbanki may produce research on a company where they (or another member of the Landsbanki Group) are also providing corporate finance services to, or dealing on a principal basis in the shares of, that company. In such cases (where possible) the relevant relationships are disclosed on the research, and Landsbanki’s procedures prevent other employees or third parties influencing the contents of analyst’s research or recommendations.
- When Landsbanki is handling client orders, Landsbanki may discuss the contents of that order with other employees or clients in order to try to find the “other side” for that order. We consider that so doing will be in the best interests of our client.
Organisational means of managing conflicts
Landsbanki and other members of the Group may use Chinese Walls to ensure that, for example, information on corporate finance and capital markets activities is not available to employees who may be engaged in dealing activities with clients or for Landsbanki itself. Where we use Chinese Walls, we also use management structures that support these restrictions on the flow of information, and we monitor to ensure that information does not flow from one side of the Chinese Wall to the other unless a member of staff is deliberately being taken "over the wall".
Landsbanki operates a personal account (“PA”) dealing policy in line with the Group P A Dealing Policy that requires all employees to have PA trades approved before dealing to ensure that dealing does not occur in securities in circumstances where such dealings should be restricted.
All clients should review the research disclaimers that appear on our research. However, in the production and distribution of research, Landsbanki endeavours to ensure that they manage their conflicts of interests fairly and that the research is clear, fair and not misleading. Our policies on production of research can be found on our website. We release research simultaneously to our clients and internally at Landsbanki to ensure that our employees cannot deal either for themselves, the Landsbanki Group companies or their clients ahead of the general research publication.
Where we do not consider that structural methods of conflict management such as those outlined above are sufficient to manage a conflict, Landsbanki may choose to disclose specific conflicts to clients and to ask for their informed consent to continue to act notwithstanding the existence of any such conflict.
Further information
Further information on these conflict management methods is available from your usual contact or our Compliance Department.