An adviser, whilst acting for a client, has identified a conflict of interest which they...

Advisers must identify, manage, and where possible avoid conflicts of interest to ensure fair client outcomes. If a conflict arises that cannot be effectively managed through controls and cannot be mitigated to the point where the client’s interests are protected, the appropriate action is to stop acting in that matter. Withdrawing from the transaction prevents the adviser from placing themselves in a position where their duty to the client could be compromised by competing interests, such as the firm’s interests, another client’s interests, or the adviser’s personal interests. Simply acting without charge does not remove the conflict, because the conflict is about competing duties and incentives, not only remuneration. Closing the client’s account is disproportionate and not necessary when the issue relates to a specific transaction. Registering the conflict with the regulator is not the correct control; conflicts are managed through firm policies, disclosure where appropriate, and withdrawal where necessary. CISI exam framing typically emphasises that where conflicts cannot be managed to avoid harm, the adviser must not proceed.