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.
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.
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.
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.
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
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.