Chrysanthou Mylona 1-3030, Panaghides Building, Episkopi, Cyprus, 350
Room 2a 14/f Chun Wo Commercial Centre, 23–29 Wing Wo Street, Central, Hong Kong
1.1. This Conflicts of Interest Policy establishes the principles for identifying, preventing, and managing conflicts of interest in the activities of Veritas Advisory Group Limited (hereinafter referred to as the “Company”). This Policy, including all terms and provisions, has been individually developed taking into account the Company’s business activities, internal rules, and operational model. The document has been prepared with the involvement of qualified professionals (including legal and audit specialists) and reflects the actual processes applied by the Company in its interaction with website visitors and clients.
1.2. The purpose of this Policy is to ensure independence of professional judgment, protection of client interests, and maintenance of high standards of professional integrity.
1.3. The Company acts honestly, objectively, and independently in the provision of its services.
2.1. This Policy applies to all employees, consultants, contractors, and partners of the Company.
2.2. The Policy applies to all projects, engagements, and client interactions.
2.3. The Policy covers actual, potential, and perceived conflicts of interest.
3.1. A conflict of interest arises where the interests of:
3.1.1. the Company and a client;
3.1.2. two or more clients;
3.1.3. an employee or partner and a client
are in conflict or may affect the objectivity of decision-making.
3.2. A conflict may arise on an actual or potential basis.
4.1. Conflicts of interest may include:
4.1.1. representation of opposing parties;
4.1.2. conflicts between current and former clients;
4.1.3. personal or financial interests of employees;
4.1.4. commercial or other incentives influencing decisions;
4.1.5. situations that may create an appearance of bias.
5.1. Prior to engagement, the Company conducts a conflict of interest check.
5.2. The check includes:
5.2.1. analysis of current and former clients;
5.2.2. identification of parties and affiliated persons;
5.2.3. assessment of potential overlaps of interests.
5.3. The results of the check are documented.
5.4. The Company does not accept an engagement where a conflict cannot be properly managed.
6.1. A conflict of interest may arise at any stage of the engagement.
6.2. Employees are required to promptly report identified risks.
6.3. The Company assesses the situation and takes appropriate measures.
7.1. Depending on the circumstances, the Company may:
7.1.1. decline the engagement;
7.1.2. terminate services;
7.1.3. implement internal control measures (including information barriers / Chinese walls).
7.2. The Company may continue engagement only where the conflict:
7.2.1. can be effectively managed;
7.2.2. does not prejudice client interests;
7.2.3. complies with applicable law and professional standards.
8.1. Where permitted by law, the Company may proceed in the presence of a potential conflict only after disclosure to the client.
8.2. Disclosure includes:
8.2.1. description of the conflict;
8.2.2. associated risks;
8.2.3. measures taken to manage the conflict.
8.3. Explicit written consent of the client is required.
8.4. The Company reserves the right to refuse engagement even where consent has been provided, if the conflict is deemed unacceptable.
9.1. The Company reserves the right to refuse engagement where a conflict of interest exists.
9.2. The Company may suspend or terminate services where a conflict is identified during the course of engagement.
9.3. Decisions are made taking into account applicable law and client interests.
10.1. Conflict checks are conducted in compliance with confidentiality requirements.
10.2. Information obtained is used solely for conflict assessment purposes. Upon achievement of such purposes or where processing is no longer necessary, data shall be deleted, destroyed, or anonymized, unless retention is required by law.
10.3. Information is not disclosed to third parties except where required by law.
11.1. The Company maintains independence in the provision of services.
11.2. Employees are prohibited from engaging in activities that may compromise objectivity.
11.3. Any factors affecting independence must be disclosed and assessed.
12.1. The Company maintains records of all identified conflicts.
12.2. The following are documented:
12.2.1. results of conflict checks;
12.2.2. decisions taken;
12.2.3. measures implemented.
12.3. Records are retained in accordance with applicable legislation.
13.1. All employees and partners are required to comply with this Policy.
13.2. They are required to:
13.2.1. identify conflicts;
13.2.2. report them in a timely manner;
13.2.3. avoid situations that compromise independence.
13.3. Breach of this Policy may result in disciplinary and legal consequences.
14.1. The Company complies with applicable legal, regulatory, and professional standards.
14.2. This includes cross-border requirements and industry best practices.
15.1. The Company reserves the right to amend this Policy.
15.2. Amendments become effective upon publication.
16.1. For matters related to conflicts of interest, the Company may be contacted at: info@veritas-advisory-group.com
