Conflict of interest control and stakeholder reporting
1) Stakeholder report
In compliance with Article 14 of the Guidelines for the Establishment and Activity of Portfolio Management Companies, in the event of a conflict of interest between the portfolio manager and the client, Sabedgardan Sarmayeh Iranian considers the interests of the client to be the priority. The instructions for archiving and circulation of customer information deal with the development of necessary restrictions to maintain the confidentiality of customer information and limit access to unnecessary information for employees not related to the basket. Also, if the portfolio manager or his employees are interested in the purchase and sale of shares, they will disclose the report according to Article 27 of the instructions for portfolio management.
2) Control of conflict of interest
According to the requirements set in Article 27 of the instructions for the establishment and operation of portfolio management companies, a notification from the Securities and Exchange Organization regarding the submission of periodic reports on the beneficiaries in order to monitor the activity of the portfolio management company and control the possible conflict of interest between the portfolio management company and the approved investors. In this regard, Sabedgardan Sarmayeh Iraniyan will submit its report periodically based on the mentioned article and in order to build the trust and satisfaction of the stakeholders after the start of the company's work. The article is presented in detail below:
1) the specifications of the securities,
2) Description of the interests of the beneficiary in that bond,
3) the date of becoming a beneficiary and the date of termination of the beneficiary (if the beneficiaries of the subject of this article were terminated before the date of the report),
4) Information on the purchase and sale of securities mentioned in the name of the customer from the time of becoming a beneficiary or the date of the previous report, whichever is later, to the termination of the beneficiary or the date of the report, whichever is earlier (including: the number of securities traded, the date of the transaction, the price of the transaction, the amount transaction and in case of access, details of the transaction party separately for each security),
5) Information related to keeping the aforementioned securities in a special portfolio from the date of becoming a beneficiary or the date of the previous report, whichever is later, to the termination of the beneficiary or the date of the report, whichever is earlier (including the number of securities held, the closing price of each sheet and the closing price the whole).
Note 1: If a person gains or loses directly or indirectly from the change in the price of a security, or that security creates rights or benefits for him, or benefits from the transactions of that security, or is considered the issuer of the security, then The mentioned index is considered to be a beneficiary in relation to Anurqa Yebahadar. Therefore, a person is considered a beneficiary of a bond under the following conditions:
1) if he is the owner of the security;
2) in case he has given or received the authority to buy or sell securities to someone else;
3) if he has borrowed or lent the securities;
4) In case he has committed to underwriting or selling securities, or has accepted marketing for underwriting or selling securities, or is a consultant to the publisher in the field of offering securities, or has participated in these cases with others;
5) In the event that it is the publisher of the securities.
Note 2: The employees of the portfolio manager are obliged to report the matter in full detail to the portfolio manager immediately after becoming a beneficiary or knowing about the beneficiary of any of their related parties. In case of request by the persons referred to in paragraphs 2 to 7 of Article 26, the basket operator will be obliged to provide the details of this information to the said persons. This information is provided to the customers within the limits specified in this article, and the details of the information are kept confidential by the bank manager and are available to the customers or other employees (with the exception of the employees who are responsible for preparing the report on the subject of this article for the auditor, trustee and customer are in charge) is not included.