Global Conflicts of Interest Policy
This Conflicts Policy is owned by Piper Sandler Companies and covers conflicts that may exist within each affiliated company as well as at the firm level. This policy applies equally to Piper Sandler Ltd pursuant to the requirements of the Financial Conduct Authority (“FCA”) and UK MiFID II meaning together the Markets in Financial Instruments Directive (EC/2014/65/EU) as it forms part of domestic law by virtue of the European Union (Withdrawal) Act 2018 (the “EUWA”) and the Markets in Financial Instruments Regulation (EC/600/2014) as it forms part of domestic law by virtue of the EUWA.
Piper Sandler Companies is a U.S.-based public holding company for its financial industry group of affiliates, including Piper Sandler & Co., member SIPC and NYSE; Piper Sandler Ltd., authorized and regulated by the U.K. Financial Conduct Authority; and Piper Sandler Hong Kong Ltd., authorized and regulated by the Hong Kong Securities and Futures Commission. Piper Sandler also offers investments in private equities strategies and fixed advisory services that offered through separately registered advisory affiliates, which, together with all affiliated companies are herein referred to as “Piper Sandler”.
Piper Sandler conducts its business under the premise that conflicts of interest must be managed in accordance with this policy and the Firm’s overriding objective of treating its clients fairly. Piper Sandler’s supervisory systems and compliance controls operate on both a Firm-wide and local business unit basis with a view to ensuring the relevancy and effectiveness of our systems and controls.
Conflicts of interest present a challenge in the financial services industry in which Piper Sandler participates. Financial services firms frequently act as intermediaries whether as a financial advisor, investment banker or in another capacity, and must manage competing interests in these situations. At Piper Sandler, we continually strive to avoid conflicts of interest where possible and otherwise to manage them as effectively as we can, first by identifying the conflict and then by eliminating it, disclosing it or mitigating it in some other way.
The variety of actual and potential conflicts of interest we face is significant, and changes as the markets and the industry evolve. Further, there is no "one-size-fits-all" approach to identifying or managing conflicts of interest. Each actual and potential conflict must be identified and then analyzed individually. This is on ongoing challenge, but one that we believe is essential to earning our clients’ trust.
From time to time, we may identify actual or potential conflicts of interest that we believe could benefit from some form of disclosure, including disclosure on this Web site. These disclosures and the discussions of particular issues may be updated, supplemented or modified from time to time, and we reserve the right to change our approach to any particular issue described and/or any related policies or procedures in our discretion and without prior notice.