It is therefore said that the agent has a duty not to be in a situation where personal interests and fiduciary duties are contradictory, a duty not to be in a situation where his fiduciary duty conflicts with another fiduciary duty and not to benefit from his fiduciary position without explicit knowledge and consent. An agent cannot have a conflict of interest. If it is established that a member of a board of directors is in breach of his fiduciary duty, he may be held liable by the company itself or its shareholders. In 2014, the Law Commission (England and Wales) examined the fiduciary duties of investment intermediaries, in particular the obligations of pension agents. They commented that the term “fiduciary” is used in many different ways. .