Conflicts of Interest Policy Template

Protect Your Clients. Protect Your Firm. Meet SYSC 10 Requirements.

Fully aligned with SYSC 10 | COBS 2.3 | FCA Principle 8 | Consumer Duty (PRIN 2A)

FCA Principle 8 is non-negotiable: "A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client." Yet many firms struggle to document exactly how they identify, prevent, and manage conflicts. This comprehensive policy template gives you a complete, regulatory-aligned framework—ready to implement.

The FCA's Expectation Is Clear

Under SYSC 10.1.10R, every authorised firm must establish, implement and maintain an effective written conflicts of interest policy. Is yours fit for purpose?

Why Conflicts of Interest Management Matters

Poor conflicts management exposes your firm to significant risks:

• Regulatory Action: The FCA actively reviews conflicts arrangements during supervisory visits and can take enforcement action for inadequate controls
• Consumer Duty Breaches: Unmanaged conflicts can directly undermine good customer outcomes—a core PRIN 2A requirement
• Inducements Failures: COBS 2.3 and 2.3A impose strict requirements on fees, commissions and non-monetary benefits
• Reputational Damage: Client trust erodes rapidly when conflicts are perceived to compromise advice or service quality
• Personal Liability: SMF holders can be held personally accountable for systemic conflicts failures
• Compensation Claims: Clients harmed by conflicted advice may seek redress through the FOS or litigation

Comprehensive Regulatory Coverage

SYSC 10 – Conflicts of Interest

• SYSC 10.1.3R: Identification of conflicts
• SYSC 10.1.6R: Record keeping requirements
• SYSC 10.1.7R: Organisational arrangements
• SYSC 10.1.8R: Disclosure requirements
• SYSC 10.1.10R: Written policy requirement
• SYSC 10.1.10AR: Annual review obligation

FCA Principles & Consumer Duty

• Principle 1: Integrity in business conduct
• Principle 6: Customers' interests and fair treatment
• Principle 8: Fair management of conflicts
• Principle 12 (Consumer Duty): Delivering good outcomes for retail customers

COBS – Inducements Rules

• COBS 2.1: Acting in best interests of clients
• COBS 2.3/2.3A: Inducements requirements
• Quality Enhancement Test: Detailed guidance included
• Prohibited Inducements: Coverage for restricted firms

The Conflict Management Hierarchy

The FCA expects firms to apply this hierarchy—our template embeds it throughout:

1

PREVENT

Avoid conflicts wherever possible

→

2

MANAGE

Effective controls where prevention fails

→

3

DISCLOSE

Last resort only—with approval

Important: SYSC 10.1.8AG warns against over-reliance on disclosure as a conflict management tool.

Your Complete Policy Framework

A professionally drafted, fully editable Conflicts of Interest Policy with built-in register templates, regulatory citations, and comprehensive coverage of inducements and gifts & hospitality.

What Makes This Template Essential

Full SYSC 10 Alignment

Every requirement addressed—from identification through to annual review and record-keeping obligations.

Consumer Duty Integrated

PRIN 2A woven throughout, ensuring your conflicts framework supports good customer outcomes.

Inducements Framework

Complete coverage of COBS 2.3/2.3A including the Quality Enhancement Test for permitted inducements.

Gifts & Hospitality Section

Ready-to-use thresholds, approval levels, and recording requirements.

Organisational Arrangements

Information barriers, remuneration controls, supervision structures—all documented.

Governance Framework

Clear responsibilities for Board, SMF holders, Compliance, and all staff.

Complete Template Contents

• Introduction & Purpose – Policy objectives aligned with regulatory requirements
• Regulatory Framework – PRIN, SYSC, and COBS requirements mapped and referenced
• Scope & Application – Coverage for employees, directors, SMF holders, contractors, and ARs
• Comprehensive Definitions – Conflicts, inducements, material interests, relevant persons
• Conflict Identification – SYSC 10.1.4R criteria and firm-specific scenario frameworks
• Management Arrangements – Information barriers, supervision, remuneration controls
• Inducements Section – Permitted/prohibited inducements with Quality Enhancement Test
• Gifts & Hospitality Policy – Thresholds, approvals, and recording requirements
• Disclosure Requirements – When, how, and approval protocols for last-resort disclosure
• Record Keeping – Retention periods and documentation requirements
• Training & Awareness – Induction, annual refresher, and policy update training
• Governance & Responsibilities – Board, Compliance, SMF, and staff accountabilities
• Review & Annual Assessment – Meeting SYSC 10.1.10AR requirements
• 
  

🎁 Included Appendices

Appendix A

Regulatory Citations Table

Quick reference to all relevant FCA Handbook provisions

Appendix B

Conflicts of Interest Register Template

Ready-to-use register format for SYSC 10.1.6R compliance

"Managing conflicts of interest fairly is fundamental to maintaining trust and integrity in financial services. This isn't optional—it's Principle 8."

Who Is This Template For?

This Conflicts of Interest Policy Template is designed for:

• Investment Firms – Meeting MiFID-derived conflicts requirements
• Mortgage & Finance Brokers – Managing commission and panel relationships
• Insurance Intermediaries – Addressing insurer/distributor conflicts
• Wealth Managers & IFAs – Independent advice and portfolio management obligations
• Payment Services Providers – Applying conflicts principles across PSR activities
• Consumer Credit Firms – Protecting borrowers from conflicted practices
• Claims Management Companies – Meeting heightened FCA expectations
• Principal Firms – Extending frameworks to Appointed Representatives

Download Your Policy Template Today!

Demonstrate robust conflicts management. Protect your clients. Satisfy the regulator.

Complete, compliant, customisable—ready for immediate implementation.

DOWNLOAD NOW

Instant download • Microsoft Word format • Fully editable

Developed by Compliance Consultant 

Making Compliance Work

Over 20 years' experience supporting FCA-regulated firms across the UK

Veteran owned and operated - Chartered Fellow of the Chartered Institute for Securities & Investment (Chartered FCSI)

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