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CONFLICT OF INTEREST POLICY |
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To avoid conflicts of interest, people working KAB especially in the Research Department must:
• Declare in any study or suggestion they provide any potential interest they or any related persons might have
• Use reliable sources during the preparation of reports and to indicate those sources in the reports.
• Separate facts from personal opinion
• Not engage in transactions in shares during the drafting of the study, before it is completed and circulated to all interested parties, unless they state that they intend to engage in trade before the publication of the study, while informing that the outcome of the study might substantially impact the value of these financial instruments
• Not be susceptible to influence by other departments and individuals and to report to the Internal Auditor any attempts to influence the impartiality of the analyst
• In the event where there is unavoidable conflict of interest, refuse to carry out studies and allow such studies to third companies
• Support their recommendations with scientifically proven methods and keep records that justify these recommendations.
• If a member of the Research Department is also a member of the Investment and Investment Strategy Committee, they are prohibited from making selective references to the Commission on companies listed on the exclusion list of the Research Department.
• Transmit and execute their personal trades through other members or employees of the Firm (e.g. via the Reception and Transmission Department)
• Not trade shares, commodities, foreign exchange and derivatives through other companies except where there are special circumstances (Margin Account). To open such accounts, they should inform the Firm’s management. They also need to communicate the movement of their portfolio on a monthly basis to the Internal Auditor
• Not enter, either personally or related person to them, in trading shares and not to prepare reports
• With insider information (inside information).
• Designed to manipulate the price of financial instruments traded (market manipulation).
• Maintain the Code of Professional Conduct of Investment Firms and comply with any instructions of Supervisory Authorities or of the Firm.
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