Purpose
Environmental certificate markets rely on trust, clarity, and impartial judgement.
A conflict of interest — real or perceived — can distort decisions, harm counterparties, and undermine market integrity.
This policy explains:
- what a conflict is
- how we identify them
- how we manage them
- how we disclose them
- how we prevent them from influencing any trade
Our commitment is simple: decisions must be made for the right reasons, not hidden ones.
1. What counts as a conflict of interest
A conflict exists when personal, financial, or organisational interests could:
- influence a decision
- benefit someone unfairly
- create divided loyalties
- compromise impartiality
- undermine trust
Conflicts may be:
Actual
The conflict exists right now.
Potential
A situation could reasonably develop into a conflict.
Perceived
Even if nothing improper has occurred, the situation looks like a conflict from the outside.
Perceived conflicts are treated as seriously as actual conflicts.
2. Examples of conflicts in certificate trading
A. Personal or financial benefits
- staff holding personal positions in REGOs, GOs, RGGOs, I-RECs
- accepting gifts, incentives, or favours from counterparties
- trading based on personal advantage rather than client interest
B. Information misuse
- using confidential counterparty interest to take a proprietary position
- sharing one counterparty’s order flow with another
C. Undisclosed relationships
- personal relationships with individuals at counterparties
- family connections to suppliers, traders, auditors, or brokers
D. Competing obligations
- working for or advising another certificate trader
- external business activities that overlap with our market
E. Organisational conflicts
- company positions or inventory that may bias trade recommendations
- revenue targets influencing impartial pricing or execution
- pressure to prioritise certain counterparties
If there is any doubt, the situation is treated as a conflict until assessed.
3. Our approach: disclose, manage, eliminate
We use a three-tier model:
1. Disclose
The individual must notify compliance immediately.
No judgement calls.
No waiting to “see if it matters.”
2. Manage
Compliance decides the appropriate mitigation, which may include:
- removing the individual from the transaction
- introducing a second reviewer
- enhanced oversight
- freezing involvement until resolved
3. Eliminate
If a conflict cannot be fully mitigated, the activity stops.
We will cancel or decline trades rather than compromise integrity.
4. Mandatory disclosure obligations
All staff and relevant contractors must disclose:
- personal investments related to environmental certificates
- outside employment or advisory roles
- close relationships with counterparties
- gifts, hospitality, or benefits offered
- any situation that could create divided loyalty
Disclosures must be:
- prompt
- accurate
- complete
Failure to disclose is treated as a disciplinary issue, even if the conflict was harmless.
5. Gifts and hospitality
Gifts or hospitality are allowed only when:
- modest
- infrequent
- transparently declared
- not connected to an active transaction
- approved according to internal guidelines
Anything excessive, timed suspiciously, or intended to influence decision-making is prohibited.
6. Information barriers
We maintain strict controls to prevent misuse of information:
- confidential counterparty data is never shared externally
- access to pricing, order flow, or positions is restricted
- staff cannot use internal information for personal gain
- sensitive information is logged and monitored
- no one trades on knowledge of upcoming orders or interest
If someone even appears to gain advantage from private information, they are removed from the process.
7. Company-level conflicts
We manage potential organisational conflicts by:
- restricting proprietary trading
- separating sales, trading, and compliance functions
- ensuring counterparty instructions are prioritised
- disclosing situations where our interests diverge from yours
- prohibiting “house-first” execution practices
- preventing targets or incentives from skewing judgement
If company revenue conflicts with market integrity, integrity wins.
8. Handling a conflict once identified
When a conflict is declared or detected:
- Compliance logs it
- Impact is assessed
- Instructions are issued (removal, oversight, or pause)
- Controls are applied and monitored
- A record is maintained for audit
- The conflict is reviewed periodically until closed
We document everything — not because we expect problems, but because good governance demands proof.
9. Zero tolerance for misuse of position
We take disciplinary action (including dismissal or termination of relationships) if anyone:
- hides a conflict
- misuses confidential information
- prioritises personal benefit
- favours one counterparty for improper reasons
- creates or exploits a conflict intentionally
A conflict is not a problem — hiding one is.
10. Reporting concerns
If you think someone is operating with a conflict of interest:
Email: compliance@energymarketingandtrading.com
Anonymous reporting: [secure link]
Reports are investigated confidentially.
Retaliation is strictly prohibited.
Why this matters
Conflicts of interest, even small ones, can:
- distort prices
- damage client trust
- misrepresent certificate quality
- undermine execution fairness
- harm market integrity
- expose the business to regulatory risk
Our policy ensures decisions are driven by integrity, not hidden incentives.