Information Conflicts

Where we have directly relevant and material information in connection with two clients, then the duty to disclose the information to one, may conflict with the duty owed to the other to safeguard the same information owed to the other. This can be resolved in many (but not all) cases, but only with careful action; the express and informed consent of both sides, provided that the information in question is not so material that it calls into question the validity of the informed consent. If you suspect you or the firm might have an Information Conflict, then you should contact the MLRO. You must not, for any reason, discuss this with a colleague, as doing so may prevent the possibility of using an €˜Information barrier' or €˜Chinese walls' to allow us to carry on acting.

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