At Walter Graham, we understand that situations may arise where a client's interests could potentially clash with those of our firm, our staff, or other clients. Our primary guiding principle is that our employees must always prioritize the interests of our clients above their own and those of Walter Graham, including its directors and staff members.
Ensuring integrity and exercising sound judgment and discretion are essential to uphold our standards of good governance and effective risk management when conflicts occur.
Such conflicts may arise for different reasons, such as when our employees engage in personal trading activities or when they exchange hospitality with clients.
Walter Graham has comprehensive internal policies and procedures in place to handle these situations. Additionally, our investment advice and order execution services for clients adhere to strict policies to guarantee suitability and best execution.
Walter Graham is committed to treating all clients fairly and equitably.
When a conflict of interest is identified, it must be reported to our Risk and Compliance team, which will provide guidance on the necessary actions to mitigate or manage the conflict and will document the conflict and the measures taken in a centralized register.
The Executive Committee works closely with the Risk and Compliance team to oversee and manage conflicts of interest and conducts periodic reviews of the Conflicts of Interest register to review the nature and frequency of conflicts and to implement additional controls as needed to ensure that clients' interests remain our first top priority.
Furthermore, Walter Graham commits to transparency and ethical conduct in all our dealings, continually updating our policies to adapt to new challenges and ensure the highest standards of client service and trust.
