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conflicts of interest policy and inventory

Identification of Conflicts

The Principals in conjunction with the business line manager together with Legal and Compliance take respnsability for identifying and designing conflict management controls faced by the Firm in its day to day business in the Conflicts Inventory below. This inventory will be periodically reviewed or updated when a new conflict is identified.

Conflict Avoidance

Where a conflict is identified, the Firm will seek to organise its business activities in a manner which avoids such a conflict. However, the avoidance of all conflicts is generally not feasible in a commercial environment.

Conflict Management

Where conflicts are unavoidable, the Firm will take appropriate measures to mitigate and manage such conflicts in a manner that seeks to ensure that the Firm or its Personnel are not advantaged, and that no Client is disadvantaged.

Conflicts Disclosure

Where the Firm is not reasonably confident that it is able to manage a particular conflict to adequately protect the interest of a Client, the general nature and/or sources of conflicts of interest will be clearly disclosed to the Client before undertaking any business.

Conflict Monitoring

The Firm has implemented a number of procedures and controls to detect conflict situations as they arise, and the Principals will update the Conflicts Inventory accordingly. Once conflicts have been identified, further procedures and controls monitor the effectiveness of the management arrangements of such conflicts.

In addition, the Firm’s compliance monitoring programme incorporates a certain number of the specific tests aimed at reviewing its performance in the management of conflicts that the Firm has indentified.

Education and Awareness

All Personnel receive a copy of the Firm’s Compliance Manual containing the Firm’s conflicts arrangements. In addition, all Personnel are required to give an undertaking of adherence to the Firm’s compliance procedures, including personal account dealing and receipt of gifts and inducements.

All Personnel also receive both formal and informal training in respect of conflicts of interest generally, and on specific or potential conflicts to the Firm.