Nume - Conflicts of Interest Policy

Purpose

Sprout Financial Ltd (trading as “Nume”) is committed to maintaining the highest standards of integrity and transparency. To ensure our decisions are always in the best interests of our customers, we have established this Conflicts of Interest Policy.

It is designed to identify, disclose, and manage any potential, perceived, or actual conflicts of interest that may arise in our business activities.

Scope

This policy applies to all Nume employees, contractors, and representatives (“Nume Representatives”) and covers all interactions with customers, suppliers, partners, and other third parties.

Policy Standards and Principles

As an FCA-regulated firm, Nume must maintain effective arrangements to identify and manage conflicts of interest that could adversely affect a client’s interests. Where conflicts cannot be avoided, we must ensure that they are disclosed clearly to clients so they can make informed decisions about continuing to engage with us.

In line with the Financial Conduct Authority (FCA) requirements and the Senior Management Arrangements, Systems and Controls (SYSC 10.1) of the FCA Handbook, Nume adheres to the following principles:

FCA Principle 1: A firm must conduct its business with integrity.
FCA Principle 6: A firm must pay due regard to the interests of its clients and treat them fairly.
FCA Principle 8: A firm must manage conflicts of interest fairly, both between itself and its clients and between one client and another.

This policy sets out Nume’s arrangements for identifying, managing, and preventing conflicts of interest that may arise during the course of business. It applies to:

Conflicts between Nume and its clients;
Conflicts between Nume clients; and
Personal conflicts that may compromise an individual’s professional judgement or objectivity.

Commitment to Fairness and Transparency

Nume takes all reasonable steps to prevent conflicts of interest from negatively impacting our clients. We maintain internal systems, training, and controls to support the identification and management of such conflicts. Where unavoidable, we will communicate any relevant conflicts to clients in a fair, clear, and transparent manner.

Definition of a Conflict of Interest

A conflict of interest arises when a Nume Representative’s personal interests — or the interests of a partner, family member, or associate — could improperly influence, or appear to influence, their decisions or actions on behalf of Nume.

Examples include:

Having a financial interest in a customer, supplier, or competitor.
Accepting gifts, favours, or hospitality that may influence judgment.
Engaging in outside activities that interfere with duties at Nume.
Close personal relationships that could impact decision-making.

Identification of Conflicts

Conflicts of interest are identified through ongoing review and oversight processes that take place:

When developing or launching new products or services;
When entering into or reviewing contracts and commercial arrangements;
When onboarding new partners, suppliers, or representatives;
As part of regular compliance monitoring and internal audits; and
Whenever there are material changes in Nume’s business activities or structure.

All Nume Representatives are responsible for remaining alert to potential conflicts in their daily work and for promptly escalating any concerns to Compliance for review and documentation.

Disclosure of Conflicts

All Nume Representatives must disclose any potential or actual conflicts as soon as they are identified.
Disclosures are reviewed by Compliance, and mitigation steps are recorded in our Conflicts Register.
An annual declaration of conflicts is required from all staff.

Managing Conflicts

When a conflict is identified, Nume may take actions such as:

Recusal: The individual is removed from the decision.
Reassignment: Work is given to another staff member.
Disclosure: Customers are informed before proceeding.
Termination: In serious cases, the relationship may be ended.

All management actions are documented.

Gifts & Hospitality

Nume Representatives are prohibited from accepting gifts, hospitality, or other benefits from customers, suppliers, or partners that could — or appear to — influence their judgment. All offers must be reported to Compliance.

Monitoring & Training

Nume regularly monitors compliance through internal audits.
Any breaches may result in disciplinary action.
Staff receive training on this policy, with annual refreshers.

Disclosing Material Conflicts

Nume will disclose any material conflicts to customers where relevant. A conflict is material if it is something a reasonable customer would expect to know and it may influence their decision-making.

Disclosures will:

Be made clearly, before the customer makes a decision.
Include enough detail for the customer to make an informed choice.
Explain how the conflict is managed or mitigated.

Examples of Disclosable Conflicts

Examples of conflicts we would disclose include where:

Nume has a financial interest in a recommended product.
Nume or its staff receive significant benefits from suppliers.
Nume refers customers to a partner where we may receive a commercial benefit.

Annex 1: Mortgage Broker Referrals

This ensures transparency while allowing customers to make an informed decision.

Nume may refer customers to a mortgage broker for mortgage advice.
Nume may receive a commercial benefit from such referrals.
Customers will always be informed of this relationship before any referral is made.
Customers are under no obligation to use the referred broker and may choose their own adviser.
Referrals are only made with the customer’s explicit consent.