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Key points

  • Ensure you have adequate arrangements in place to identify, monitor and manage your own conflicts of interest.
  • If you help set up a conflicts process for trustees, make sure it includes a conflicts policy, register of interest, declarations and advance planning.

Managing your own conflicts of interest

You should have adequate arrangements in place for identifying, managing and disclosing your own conflicts of interest.

You should make trustees aware of any conflicts of interest that might or do arise when you refer services or products for which you may gain some form of financial or non-financial benefits.

Ensure that trustees understand when they’re being given independent advice and when they’re being offered a service or product from a party related to an adviser.

Trustee conflicts of interest

Actual or potential conflicts of interest may arise for trustees of DB schemes, eg when they’re involved in funding negotiations.

There may be acute or pervasive conflicts associated with a trustee’s role, eg where they are also the finance director, in respect of which they may need advice. Not all conflicts are employer related – they can also arise for trustees who, for example, are scheme members or who hold trade union representative roles.

You should help trustees to have processes in place to manage these types of issues.

Setting up a conflicts process for trustees

Trustees may ask you to help them set up a process to identify, monitor and manage any conflicts of interest, including potential conflicts, for those involved in running their DB scheme. This includes trustees, advisers and service providers. Such a process should include the following controls:

  • agreeing a conflicts policy setting out the scheme's approach to dealing with conflicts – this should cover the process to identify and monitor conflicts and outline options for managing these
  • maintaining a register of interests for recording all actual or potential conflicts
  • a process for declarations when trustees, advisers and service providers are appointed, including ongoing declarations by advisers and service providers as soon as they arise and declarations at the start of trustee and sub-committee meetings
  • advance planning to identify conflicts that may occur in the future and available options for managing these

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