Conflicts of interest

The firm is dedicated to delivering long-term performance and customer service. We always put our customers first – their needs and interests are our priority.

We are determined to treat customers fairly at all times and as a principle, we do not provide services in a manner that might unfairly advance the interests of one customer over another.

Our conflicts of interest policy outlines how we identify, prevent or manage a potential conflict of interest and remove or minimise any risk of disadvantaging our customers.

What are conflicts of interest?

Conflicts of interest are situations that could occur as we provide our services, which may result in a material risk of damage to the interests of a customer.

When assessing whether a conflict of interest has arisen, we look at whether we or any individual connected to our business (for example, a member of staff or connected person such as a spouse, partner, children or close relative):

• Is likely to make a financial gain, or avoid a financial loss, at the expense of a customer
• Has an interest in the outcome of a service or transaction that is different from the customer’s interest
• Has a financial or other incentive to favour the interests of one customer or group of customers over another
• Conducts the same or similar business as the customer
• Has received or will receive an inducement for the service provided from a person other than the customer, other than the standard payment for that service (this could be monies, goods or services)

Here are some examples of conflicts of interest that could arise:

• Outside business interests, such as directorships of a member of staff or connected person at other companies
• Misuse of material non-public information when a staff member is conducting a personal transaction
• Prioritising trades or suitable investment opportunities for one customer to the disadvantage of another
• Receiving or providing gifts or entertainment that could induce us not to act in the best interest of our customers
• A remuneration structure that could influence our employees’ behaviour to the detriment of our customers
• Promoting our own funds above other third-party funds, by giving them unequal prominence and exposure

Identifying and managing conflicts of interest

All staff participate in an annual training programme that includes guidance on how to identify a potential conflict of interest.

If a conflict of interest is reported or detected through our monitoring activity, it is reviewed and added to our conflicts of interest register. The action we take to prevent or manage the conflict depends on the severity of the risk to the customer’s interests.

We prevent and manage conflicts by:

• Internal controls (our internal policies and procedures)
  • All staff members participate in regular training and activity is monitored to ensure that processes are followed correctly
  • All conflicts of interest are reviewed at least annually and more frequently if required
  • Internal policy decisions have been taken to prevent conflicts of interest – for example, all employees receive a basic salary only with no bonus / discretionary element, to ensure that behaviour is aligned to customer outcomes rather than personal incentive
• Termination/avoidance
  • The potential impact of some conflicts of interest may be so significant that our internal controls are not considered adequate
  • In that scenario, we would terminate or avoid the activity that the conflict relates to
• Disclosure
  • If the conflict of interest cannot be managed through our internal controls – for example, where the risk of damage to the customer’s interest cannot be prevented or managed – the conflict of interest is disclosed to the customer

We review our conflicts of interest policy every year to ensure our arrangements are appropriate and effectively protect the interests of our customers.