As a measure of last resort, a disclosure to clients is made (via email) if the company cannot ensure, with reasonable confidence, that the organizational and administrative arrangements in place are (or have been) sufficient to prevent or manage certain conflicts of interest, which could potentially harm the client’s interest.


If such a disclosure must be made, it shall clearly state in a durable medium:

which organizational and administrative arrangements have been established by CPFS to manage that conflict and which have not been sufficient to ensure, with reasonable confidence, that the risks of damage to the client’s interest are or will be prevented.


  • a specific description of the conflict(s) of interest that arise in the provision of investment and/or ancillary services,

  • a description explaining the general nature and/or sources of conflicts of interest;

  • the risks to the client that arise as a result of the conflicts of interest;

  • The steps taken to mitigate these risks

 The disclosure takes into account the nature of the client (client classification) to whom the disclosure is made to enable that client to take an informed decision with respect to the investment or ancillary service in the context of which the conflict(s) of interest arise.