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 company, with the objective to provide healthy and trustworthy operations and services by Saga Capital. The Compliance Officer is appointed by the company's Board of Directors and is supervised by the company's Internal Auditor.
The Compliance Officer supervises that the operations of the company are in compliance with the provisions of any relevant laws, rules and regulations that apply to the company and reports on regular basis to the Board of Directors of his duties and activities. To that end, 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 company'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 company, between the company and the company's clients on the on hand and between different clients of the company on the other hand, particularly regarding trading in financial instruments
Saga Capital's Policy on Best Execution
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.
Mr. Vilhjalmur Bergs, attorney at law, is Saga Capital's Compliance Officer, vilhjalmur@sagacapital.is.
