Conflicts of Interest Policy Summary

Set out below is a summary of the Revolut Group Conflicts of Interest Policy

The Revolut Group

This Policy applies to the Revolut Group (“Revolut”), its subsidiaries and regulated entities globally. This Policy also applies to trading and investment services that are provided by the Revolut Group where Revolut acts as an Appointed Representative.

The following activities and services are not undertaken by the Revolut Group and, accordingly, there are no identified conflicts of interest that arise or may arise from such services and activities:

  • Investment Research for external distribution
  • Investment advice to retail clients
  • Proprietary trading, or
  • Corporate finance

Conflicts of Interest Policy Summary

This statement sets out a summary of Revolut’s Conflicts of Interest Policy and includes those circumstances that have been identified by Revolut as potentially giving rise to a conflict of interest which may damage the interests of Revolut’s customers and clients. A high level overview of the systems and controls adopted to manage such conflicts and mitigate conflicts of interest risks is also included.

Other perceived conflicts of interest may exist in certain aspects of Revolut’s business which do not create a risk of damage to the interests of Revolut’s customers and clients. Perceived conflicts of interest are appropriately managed through suitable risk and compliance processes and procedures; accordingly they are not reflected here.

Conflicts of Interest are inevitable in the normal course of business and Revolut employees (including executive and non-executive directors) are required to identify and manage conflicts in accordance with Revolut’s established Conflicts of Interest Framework. The identification and management of conflicts, whether real, possible or perceived, is critical. Some conflicts of interest may be impermissible as a matter of law, regulation, or Revolut policy. Other conflicts may be permissible and Revolut has procedures and controls in place to manage and mitigate risks of customer detriment from conflicts of interest that might arise. Such conflicts of interest may exist between:

  • Revolut (including its managers, employees, or any person directly or indirectly linked to them by control) and a customer / client; or
  • Between two (or more) Revolut customers / clients

A conflict may arise where Revolut:

  • Is likely to make a financial gain, or avoid a financial loss, at the expense of a customer / client;
  • Has an interest in the outcome of a service provided to a customer / client, which is distinct from the customer’s / client’s interest in that outcome;
  • Has a financial or other incentive to favour the interests of one customer / client or group of customers / clients over the interests of another customer / client; or
  • Receives or will receive from a person other than the customer / client an inducement (i.e. a fee or a gift or entertainment) in relation to a service provided to the customer / client, in the form of monies, goods or services, other than the standard commission or fee for that service.