Conflicts of Interest Policy
1. Introduction
Bonsai Wealth Ltd (“Bonsai”, “we”, “our”, “us”) is committed to acting in the best interests of our customers at all times. This policy sets out how we identify, manage, and mitigate conflicts of interest that could arise when delivering our services.
We aim to ensure that customers are treated fairly and that our independence, objectivity, and professional judgement are never compromised.
Although Bonsai is not yet regulated, we are designing our processes to meet FCA standards ahead of obtaining authorisation. This policy reflects the FCA’s Senior Management Arrangements, Systems and Controls (SYSC) requirements for managing conflicts of interest.
2. What is a Conflict of Interest?
A conflict of interest arises where Bonsai, its employees, partners, or affiliates have competing personal, financial, or professional interests that could prevent them from acting solely in the interests of customers.
Examples include:
Where Bonsai or an employee could gain a financial advantage at a customer’s expense.
Where Bonsai’s interest in a particular product provider influences recommendations.
Where Bonsai or its employees receive inducements, gifts, or incentives from third parties.
Where an employee has external business interests that could interfere with their duties at Bonsai.
3. Identifying Conflicts at Bonsai
We actively monitor for conflicts at each stage of our services, including:
Product selection: When choosing investment products and savings providers for inclusion on the platform.
Partnerships: When forming commercial relationships with third parties such as Seccl (custodian) or Bondsmith (cash provider).
Customer advice & guidance: When our AI co-pilot or human advisers make financial suggestions.
Marketing activities: Where product placements or promotions could be influenced by financial arrangements.
Employee conduct: When employees have personal investments, external roles, or financial relationships that overlap with their work at Bonsai.
4. How We Manage Conflicts of Interest
Where conflicts cannot be fully avoided, Bonsai applies strict controls and transparency measures to ensure no customer is disadvantaged.
Our approach includes:
Conflicts register – All identified conflicts are recorded in a central log, along with the controls in place to manage them.
Disclosure – Where appropriate, we will inform customers of the conflict and explain how we are managing it.
Independent product selection – Investment and savings products are selected based on merit, cost, and suitability, not financial incentives.
Gifts & hospitality controls – Employees must declare and seek approval for any gifts or hospitality over a low monetary threshold.
External business interests declaration – Employees must declare any directorships, secondary employment, or outside commercial interests, all of which are assessed for conflicts.
Segregation of duties – Key functions (such as product selection, marketing, and compliance) are kept operationally separate to prevent undue influence.
AI & recommendation oversight – All recommendations made by the AI co-pilot are subject to regular human review to ensure neutrality and alignment with customer best interests.
Training & culture – All employees receive mandatory training on conflicts management, ethical conduct, and regulatory expectations.
5. Product & Partner Due Diligence
Bonsai partners with third parties like Seccl and Bondsmith to provide services. To prevent conflicts:
All commercial arrangements are reviewed for transparency and customer fairness.
Any revenue-sharing models are disclosed to customers.
Products and providers are assessed based on independent criteria, not preferential commercial terms.
6. Disclosure to Customers
Where a conflict cannot be fully mitigated or avoided, we will:
Clearly disclose the nature and source of the conflict.
Explain how we manage and monitor the conflict.
Ensure customers have all the information they need to make an informed decision.
We will never prioritise our commercial interests over the best interests of our customers.
7. Governance and Oversight
The Bonsai Board of Directors has overall responsibility for this policy and for ensuring a culture that promotes fairness and transparency.
Conflicts are reviewed regularly at senior management meetings.
The Compliance Team maintains the Conflicts Register and monitors adherence to this policy.
Any material conflicts are escalated to the Board for review and decision-making.
8. Recording & Reporting
All conflicts identified, along with the mitigating actions taken, are recorded in the Conflicts Register.
Employees are required to self-declare any new conflicts as they arise, including changes to personal circumstances, investments, or external roles.
A conflicts report is presented to the Board at least annually.
9. Breaches & Consequences
Failure to declare or appropriately manage a conflict of interest will be treated as a serious breach of Bonsai’s internal policies and may result in disciplinary action, up to and including dismissal.
In the event of a breach that impacts customers, Bonsai will assess whether it needs to notify the FCA (once regulated) and communicate directly with affected customers.
10. Contact
If you have any questions about this policy, or wish to raise a concern about a potential conflict, please contact our Compliance Team at:
Email: compliance@bonsaiwealth.io
This policy was approved on 1 March 2025 and will be reviewed annually.