Conflict of Interest Policy

This document outlines the policy adopted by the company regarding procedures to be followed in the event of a conflict of interest.

GreenFence provides a wide range of services and consequently conducts numerous transactions on an ongoing basis. Within the framework of these activities, situations may arise that lead to conflicts of interest, either on an ad hoc or recurring basis. This document outlines the policy adopted by the company regarding procedures to be followed in the event of a conflict of interest.


Conflict of Interest:
A conflict of interest exists when one or more individuals face competing interests, and serving the interest of one party may work to the detriment of another. A conflict of interest situation also refers to any scenario where the ability of employees to independently and impartially evaluate, judge, or make decisions is influenced or can be influenced by personal interests, whose satisfaction contradicts the company’s interests, by third-party interests, or by actions or omissions of the staff that may endanger the company’s interests or those of its clients (e.g., hindering duty performance, violating regulations and directives, failing to maintain loyalty, or actions that damage the company’s prestige and reputation).

Conflict of Interest Policy:
This policy defines the framework for identifying, managing, addressing, and avoiding conflict of interest incidents.

Financial Interest:
Anything that brings financial or monetary benefit to a person.

Any natural or legal person or association of persons who receives services provided by the company, regardless of whether they act on their own behalf or on behalf of a third party.

Related Parties:
Related parties are considered those connected to someone involved in the transaction in any of the following ways. These include the spouse or partner of that person, treated as a spouse under current law, dependent children and/or dependent adopted children of the person conducting the transaction, and other relatives who, at the time of the transaction, had been living in the same household as the person conducting the transaction for at least one year.


Purpose of Policy

The purpose of this policy is to establish a framework and provide guidelines for managing, addressing, and preventing conflict of interest incidents.

Specifically, the Conflict of Interest Policy aims to:

  1. Identify Situations: Identify situations that may lead to a conflict of interest, which could harm the interests of the client or the company.
  2. Implement Procedures: Implement appropriate procedures and operate mechanisms and systems to manage conflicts of interest.
  3. Design Preventive Strategies: Design and apply strategies with a preventive role against potential damages to clients and the company from possible conflicts of interest. 

By following this policy, GreenFence aims to ensure transparency, integrity, and the highest standards of professional conduct in all its operations.


GreenFence adopts a policy for identifying and managing conflict of interest situations and preventing inappropriate employee behavior that may lead to conflicts of interest. For these reasons, GreenFence records and monitors employee transactions. Transactions are kept on file and can be investigated whenever necessary.

Employees conducting transactions must adhere to the following guidelines:

  1. Transparency: Transactions must be conducted transparently to ensure their legality and correctness.
  2. Legal Compliance: Transactions must comply with applicable laws and regulations and must not contradict the content of this Policy.
  3. Work Duties: Transactions must not distract employees from their job responsibilities.
  4. Company Reputation: Transactions must not threaten the company’s reputation and prestige.
  5. Confidential Information: Transactions must not involve the misuse or improper disclosure of confidential information.
  6. Abuse of Power: Transactions must not result from abuse of authority.
  7. Company Interests: Transactions must not conflict with the company’s interests.


To ensure the effective implementation of this Policy, GreenFence provides the necessary training and information to its employees on conflict of interest issues. This training helps employees develop the ability to identify conflict of interest situations and, with appropriate training, manage and address them. Additionally, these training programs are designed to raise awareness among employees about conflict of interest situations by providing relevant information.

GreenFence also implements necessary procedures to timely identify potential conflict of interest situations to detect and address them. All conflict of interest incidents are recorded and maintained in a file.

In cases where preventive measures have been applied but a conflict of interest situation is deemed unavoidable and cannot be prevented, GreenFence informs its clients before executing the relevant transaction on their behalf.



This Policy extends to all activities and services provided by GreenFence to its clients and to all company employees, particularly those who, due to their job positions, conduct transactions more frequently. For the purposes of this Policy, GreenFence clients include both existing and new clients. Every transaction and activity of the company is governed by the provisions of this Policy, and its content must always be taken into consideration.