Conflicts of interest

Version 1.0 · Effective 23 October 2026

We act in the interests of our clients. A conflict of interest arises where the interests of the bank, its staff or its directors, or of one client, could differ from those of another client. This statement summarises how we manage such conflicts.

Identifying conflicts. We identify situations that give rise, or could give rise, to a conflict, including those arising from our own business, from staff and directors’ personal interests, and from payments or benefits received from third parties.

Preventing and managing conflicts. We manage conflicts through policies on personal interests, gifts and outside activities; the separation of duties; and oversight by the Compliance Officer. Directors declare their interests to the board.

Disclosure. Where a conflict cannot be managed so that a client’s interests are protected, we tell the client before acting, so that the client can decide how to proceed, or we decline to act.