Guidelines for preventing conflict of interests
Being aware of the significance of preventing conflict of interests, ALTUM have created a system of preventing conflict of interests that includes a set of several individual measures and ensures maximum defence of ALTUM and clients’ interests.
The system of preventing conflict of interests includes all ALTUM activity processes and it is based on a proactive approach, i. e. the circumstances which can cause situations of conflict of interests are identified promptly as well as measures preventing the possibility of emerging of conflict of interests initially are carried out.
To manage and prevent conflict of interests, ALTUM have laid down standards in the internal normative documents and measures preventing creation of conflict of interests are laid down in the activity processes.
When creating the organizing structure, ALTUM’s Guidelines of internal control system are followed ensuring the best corporative and risk management practices and/or requirement implementation laid down in the legislation including separation of specific fields of activity in individual structural units. The organizing structure for monitoring conflict of interests is created in a way that ensures that implementation of any activity, its control and monitoring functions are carried out in several structural units. It ensures an optimal correlation between activities to be carried out by ALTUM, their control and monitoring process.
When establishing committees and/or equivalent budgetary authorities, ALTUM’s Guidelines of internal control system are followed as well as the possibility of occurrence of conflict of interests between members of a committee and/or equivalent budgetary authority is prevented initially by determining the composition of the committee and/or equivalent budgetary authority. When carrying out the position and/or work duties, the members of the budgetary authority make decisions based on ALTUM’s interests and avoiding creation of conflicts of interests or the possibility of creating them. When making decisions, the members of budgetary authorities do not use cooperation offers lodged by ALTUM for personal benefits, i. e. when making any decisions relevant to ALTUM’s activity, every member of the budgetary authority must avoid any conflicts of interests within the scope of their activity and he/she must be independent from external conditions as much as possible and must have a desire to take responsibility for decisions made following the commonly agreed ethical principles and corporative and professional activity standards laid down in ALTUM’s Code of Ethics.
The member of budgetary authorities must report any creation of conflict of interests or its possibility to other members of budgetary authorities. When making decisions, members of budgetary authorities have no voting rights for examination of the matters where any conflict of interests exists. In case it is not possible to make a decision about the possible conflict of interests in the budgetary authority, the decision making is directed to a hierarchical superior budgetary authority sharing all the information about the conflict of interests. The member of the budgetary authority violating the guidelines of conflicts of interests takes responsibility for losses and/or damage caused to ALTUM.
ALTUM ensures a creation of remuneration system that does not affect the objectivity of the employees and interests of ALTUM or the clients and it does not create special priorities or benefits to an employee in the situations of conflict of interests.
When carrying out work duties, the employees provide objective, complete, correct and safe information on the nature of the deal as well as they share all the real, potential and apparent conflicts of interests when making decisions and considering matters which are relevant to the interests of ALTUM or the clients.
ALTUM ensures that all the information ALTUM employees provide to the clients or the potential clients personally is clear (excluding a possibility of interpretation), precise, correct (facts are not amended) as well as it is not misleading and inconsistent with activities carried out by ALTUM.
ALTUM does not permit causing situations when information available to the employees because of their work duties is unlawfully disclosed or used for goals which are not relevant to carrying out work duties or specific work tasks based on ALTUM interests.
When carrying out work duties, the employees follow the professional action and ethical standards set by ALTUM according to Altum’s Code of Ethics and prevent the creation of conflicts of interests by organizing their activity according to the interests of ALTUM and the client separating personal interests from the professional ones.
The employees avoid situations including getting involved in private activities where a conflict of interests may arise by not causing suspicion about unethical and affectable state with their actions and behaviour. The employees do not take advantage of their job position and do not use ALTUM’s resources for private interests, personal benefits or benefits of other persons.
The employees shall abstain from decision making in matters affecting their close relatives directly including hiring, work assessment, bonuses and other rewards etc.
The prevention of conflicts of interests which may arise within the framework of ALTUM employees who are public officials is additionally regulated by the law “On Prevention of Conflict of Interest in Activities of Public Officials (in LV)” and the “Law on public procurement” and other ALTUM employees are required to take it into account.
In order to educate the employees on matters of conflict of interest, ALTUM organize trainings to their employees regularly.