Conflicts of Interest Policy

Introduction

This document is the Conflicts of Interest Policy of ACC Bank plc (“the Bank”).

The Bank is committed to ensuring that our business is conducted in an honest and professional manner. All employees of the Bank are obliged to refrain from doing anything that could be reasonably regarded as creating a conflict of interest in line with their professional responsibilities.

It is the policy of the Bank to avoid any conflict of interest when providing business services to its customers. From time to time the Bank may however have interests which conflict with our customers’ interests, our policy is to identify such instances and manage them accordingly.

Identifying and Managing Conflicts of Interest

The Bank has internal procedures to enable conflicts of interest to be identified. The Bank has administrative and organisational arrangements in place to ensure that our employees act independently and in a way to safeguard the interest of our customers. Theses arrangements include:

• internal procedures for handling conflicts of interest, should they arise;
• internal rules to ensure that confidential information is dealt with appropriately;
• “Chinese Walls”, if required, which require information held by the Bank to be withheld in certain circumstances from other operating units or from persons with whom it deals in the course of carrying on another part of its business of any kind;
• procedures for governing personal dealings by the Bank’s employees;
• procedures in relation to the Bank’s internal code of conduct and ethics; and
• procedures in relation to giving and receiving of gifts, entertainment or hospitality.

If a Conflict of Interest Arises

Where an unavoidable conflict of interest arises, the customer will be advised of this in writing. A response must then be received in writing from the customer, indicating that the customer is aware of the conflict and wishes to proceed with the business before the business can be progressed further. If the customer has not been advised of any such conflict of interest they are entitled to assume that none arises. The Bank monitors the compliance of its conflicts of interest policy and related procedures on an ongoing basis.