Saga Capital emphasizes highly on compliance and is
determined to fulfill any requirements made at all times. Therefore Saga
Capital's Compliance Officer must be highly qualified and fully independent from
other executives in the bank, with the objective to provide healthy and
trustworthy operations and services by Saga Capital. The Compliance Officer is
appointed by the bank’s Board of Directors and is supervised by the Bank’s
Internal Auditor.
The Compliance Officer supervises that the operations of the bank are in compliance with the provisions of any relevant laws, rules and regulations that apply to the bank and reports on regular basis to the Board of Directors of his duties and activities.
Saga Capital has established the following rules:
Rules of Procedure of Proprietary
Trading
These rules have the purpose to promote impartiality and
equal treatment of clients in the business activities of Saga Capital, prevent
conflicts of interest and ensure the impartiality of employees and the
confidentiality and integrity in Saga Capital's trading for its own
account.
The Board of
Director's Rules of Procedure
The rules have the purpose to
ensure equal treatment of different issues executed by the Board of Directors,
honest and independent procedures by the Board and to prevent any kind of
conflict of interests in Saga Capital's business and services related thereto.
Therefore the Rules of Procedure are intended to strengthen Saga Capital's
procedures on the bank's business and services that relate in one way or the
other to individual members of the Board of Directors, including other related
legal parties. The rules also limit and govern as the Board of Director's access
to information on Saga Capital's clients.
Rules on
Anti-Money Laundering and Combat of Terrorist
Financing
These rules are established to
prevent the misuse of Saga Capital's operations and services to launder money or
to finance terrorist activities. The rules shall promote that Saga Capital
fulfils any and all requirements imposed on financial institutions in Iceland
as well as on international basis, in order to fight money laundering and
terrorist financing.
Saga
Capital's Policy for Conflict of Interest
The Policy is established to
prevent that conflicts of interests arise in the operations and service of the
bank, between the bank and the banks clients on the on hand and between
different clients of the bank on the other hand, particularly regarding trading
in financial instruments
The Compliance Officer oversees compliance with the rules and takes the initiative in interpreting the rules and taking decisions based upon them. The Compliance Officer keeps Saga Capital's employees informed of the rules and reviews the rules on regular basis.
Saga Capital's shares are not listed on a regulated
market, but nevertheless the banks emphasizes on providing thorough information
to it's shareholders on regular basis, as well as to market participants and
supervisory bodies. Saga Capital issues a monthly newsletter to its shareholders
and reports on a regular basis to the Financial Supervisory Authority in
Iceland.
Mrs. Helga Hlin
Hakonardóttir, attorney at law, is Saga Capital's Compliance
Officer, helga at sagacapital.is.