Conflicts of Interest Policy Template

This Conflicts of Interest Policy Template is an FCA-aligned guide for identifying, preventing, and managing conflicts in financial services. Built on SYSC 10, PRIN 8, CONC, and 2025 FCA updates, it ensures fair client treatment and transparency, reducing regulatory risks and harm.

It outlines processes for conflict identification, mitigation, and disclosure, along with customisable templates such as risk registers and escalation forms. Supporting SMCR accountability, audits, and FCA compliance, it fosters integrity across operations.

Includes:

• Regulatory Obligations under SYSC 10 and Consumer Credit Regulations

• Types of Conflicts Relevant to the Firm

• Conflict Identification Process

• Situations Where Conflicts May Arise

• Client vs. Client Conflicts

• Employee and Management Conflicts

• Preventive Measures and Internal Controls

• Information Barriers and Segregation of Duties

• Staff Remuneration and Incentives Controls

• Disclosure Requirements and Client Communication

• Recusal and Removal from Decision-Making

• Maintaining a Conflict of Interest Register

• Responsibilities of Senior Management and Compliance

• Monitoring and Ongoing Review

• Staff Training and Compliance Culture

• Disciplinary Consequences for Non-Compliance