Updated 03/01/2026
Coming into force on 19/01/2026

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Article 6 - Delegated Regulation 2025/2180

Article 6

Criteria for assessing the management of conflicts of interest

1.   When assessing the management of conflicts of interest, external reviewers shall ensure that the following criteria are fulfilled:

(a)

there is a conflicts of interest policy;

(b)

there is an effective compliance process that is appropriate for monitoring the implementation of the conflicts of interest policy, including board oversight;

(c)

there are procedures for training and raising awareness of the content of the conflicts of interest policy to senior management, members of the board, analysts, employees, and any other natural person whose services are placed at the disposal or under the control of the external reviewer, including before those persons first take up their duties;

(d)

an inventory of actual or potential conflicts of interest relevant to the external reviewer is kept, including proposed mitigation measures;

(e)

risk management procedures and preventative and detective controls with respect to the identification, elimination, management, and disclosure of conflicts of interest are in place;

(f)

the conflicts of interest to be eliminated or managed and disclosed in a transparent manner are identified;

(g)

the independence of analysts, employees and other persons directly involved in assessment activities is ensured.

2.   The external reviewer shall evaluate the criteria referred to in paragraph 1 prior to providing external review activities and thereafter at least once every 24 months, or as soon as the external reviewer becomes aware of significant deviations concerning the management of conflicts of interests.