(3)Conflicts of interest can arise between APAs or ARMs, on the one hand, and clients using their services to meet their regulatory obligations and other entities purchasing data from APAs or ARMs, on the other hand. Those conflicts may arise in particular where the APA or ARM is engaged in other activities, including acting as a market operator, investment firm or trade repository. A conflict of interest that is left unaddressed could incentivise APAs or ARMs to delay publication or submission of data or to trade on the basis of the confidential information they have received. APAs and ARMs should therefore operate and maintain effective administrative arrangements to identify, prevent and manage existing and potential conflicts of interest, including by preparing an inventory of conflicts of interest and by implementing policies and procedures that are appropriate to manage those conflicts and, where necessary, by separating business functions and personnel to limit the flow of sensitive information between different business areas.