Management of conflicts of interest
Nordic Issuing is an external issuing agent within Spotlight Group who owns ATS Finans AB. ATS Finans AB also conducts other types of securities operations under the business branches Sedermera Fondkommission (financial advisor) and Spotlight Stock Market (marketplace). More detailed descriptions of the management of conflicts of interest can be found on their respective websites. In order to distinguish Nordic Issuing from other activities and avoid potential conflicts of interest, there are extensively established procedures for managing conflicts of interest within the Group. Nordic Issuing functions as an external issuing agent, often when companies carry out capitalizations without financial advisors, but as a brand within the same company as Sedermera Fondkommission there is sometimes overlapping organizational management. For this reason, separate IT systems etc. have been introduced to ensure that the services provided by Nordic Issuing as an external issuing agent are separated from Sedermera Fondkommission’s operations and from Sedermera Fondkommission’s Corporate finance-related staff. Nordic Issuing will be happy to provide further information on the management of conflicts of interest in the event of further issues.
According to the Swedish Securities Market Act (2007:528), Nordic Issuing shall take all reasonable steps to identify and manage conflicts of interest arising from the provision of investment and ancillary services and to prevent the interests of clients from being adversely affected by conflicts of interest arising.
The risk of conflicts of interest arise is influenced by the organization of the business and the conduct of rules and control systems. Values and standards affect the controlled environment and the ability to manage conflicts of interest. Nordic Issuing works continuously to identify and eliminate conflicts of interest through the introduction of rules and the construction of control systems so that you as a customer can feel safe in your business with us.
All employees within Spotlight Group have a responsibility to identify and report actual or potential conflicts of interest. This is especially true in relation to new projects or assignments that Nordic Issuing undertakes. All employees of Spotlight Group receive training regarding the proper management of conflicts of interest and are aware that they are responsible for identifying situations that require reporting and management in accordance with ATS Finans’ internal regulations.
The company manages conflicts of interest through an escalation process, which is carried out in the following steps:
- Possible provision of conflict of interest information to customer
Nordic Issuing has a clear structure for burden-sharing and governance to avoid conflicts of interest through a division into different organizational units for the separation of business functions. Nordic Issuing has further through its work processes created duality in its operations so that no individual can take action in order to benefit themselves or Nordic Issuing at the expense of a customer or other counterparty. All staff within Spotlight Group also have a ban on trading financial instruments on Swedish MTFs. Prohibition of trade also applies to companies with which Nordic Issuing has a customer relationship. For further information on the management of conflicts of interest within Spotlight Group, please refer to information on the other business segments’ websites (www.sedermera.se and www.spotlightstockmarket.com respectively).