Common use of Conflicts of Interest Policy Clause in Contracts

Conflicts of Interest Policy. 29.1 In accordance with the FCA Rules we have policies in place to avoid or manage any conflict of interest which might arise between ourselves and any of our clients or between our clients. Bordier UK is required to have a Conflicts of Interest Policy to ensure that any possible conflicts between our interests and those of our clients are properly handled. This disclosure statement summarises potential conflicts and details how we address them. 29.2 Wherever we can practically do so we will endeavour to arrange our business and manage our affairs in such a way so as to avoid any conflicts of interest. This is not always possible and we have identified a number of areas where we may be unable to avoid or manage a conflict (or potential conflicts) fully and thus we are advising you of this fact. The general nature and/or source of these potential conflicts are: 29.2.1 we, or our directors, officers and employees, may have bought or sold a particular financial instrument or investment and/or have a view on a particular financial instrument or investment or issuer of investments. 29.2.2 we may combine your orders with the orders of other clients. Such aggregation may operate on some occasions to your advantage and on some occasions to your disadvantage. Where orders have been aggregated, they will be allocated to clients on a pro-rata basis. 29.2.3 we may pass orders to third-party brokers for execution in accordance with the third-party broker's order execution policy. 29.2.4 it is possible that one of our directors, officers or employees may be a director of a company in which we wish to invest. 29.2.5 in conducting our business, our directors, officers or employees may learn confidential information about our clients, prospective clients and third parties. 29.2.6 directors, officers or employees may be offered hospitality or gifts by service and product providers. 29.3 to manage any potential conflict we operate a number of polices and procedures as follows: 29.3.1 we have implemented a policy of independence with which our directors, officers and employees are required to disregard any information they receive or action they have taken in relation to one client when dealing with another. 29.3.2 we do not distribute investment research. 29.3.3 if one of our directors, officers or employees is a director of a company in which we wish to invest we will not invest in this company on a pro-active basis on behalf of discretionary clients. 29.3.4 we have Personal Account Dealing procedures to ensure that we do not compromise our dealing arrangements for clients. 29.3.5 our directors, officers and employees are required to disclose and in all cases must obtain approval from us before carrying out any outside business interest or employment. 29.3.6 our directors, officers and employees are required to maintain Confidentiality of all information entrusted to them, except where disclosure is required by law or authorised by you. Further, directors, officers and employees are not permitted to use such information for their personal gain. 29.3.7 corporate hospitality and gifts must be approved before they may be accepted or given. Any gifts received by individuals or the firm are put into a lottery in which all staff take part. 29.4 Status of this Policy: This policy does not form part of our Terms of Business, is not intended to be contractually binding or impose or seek to impose any obligations on us which we would not otherwise have whether under our Terms of Business or the FCA Rules had this policy not been disclosed to you. 29.5 A summary outlining SEI's policy with regard to Conflicts of Interest is available on request.

Conflicts of Interest Policy. 29.1 In accordance with the FCA Rules We and our Affiliates may, without prior reference to you, act in circumstances in which we have policies in place to avoid or manage any conflict of interest which might arise between ourselves and any of our clients or between our clients. Bordier UK is required to have a Conflicts of Interest Policy to ensure that any possible conflicts between our interests and those of our clients are properly handled. This disclosure statement summarises potential conflicts and details how we address them. 29.2 Wherever we can practically do so we will endeavour to arrange our business and manage our affairs in such a way so as to avoid any conflicts of interest. This is not always possible and we have identified a number of areas where we may be unable to avoid or manage a conflict (or potential conflicts) fully and thus we are advising you of this fact. The general nature and/or source of these potential conflicts are: 29.2.1 we, or our directors, officers and employees, may have bought or sold a particular financial instrument or investment and/or have a view on a particular financial instrument or investment or issuer of investments. 29.2.2 we may combine your orders with the orders of other clients. Such aggregation may operate on some occasions to your advantage and on some occasions to your disadvantage. Where orders have been aggregated, they will be allocated to clients on a pro-rata basis. 29.2.3 we may pass orders to third-party brokers for execution in accordance with the third-party broker's order execution policy. 29.2.4 it is possible that one of our directorsAffiliates has a material interest or a relationship of any description with another party which may involve an actual or potential conflict with our duty to you. We will ensure that such transactions are effected on terms which are not materially less favourable to you than if the potential conflict had not existed. A “conflict of interest” may arise in two situations: First, officers if we are providing a service to you and, beyond that, we have a material interest, relationship or employees arrangement in the transaction or product or service; or Second, we are acting for you and we or another member of our Group is acting for another client and your two interests materially conflict. We have worked to identify such conflicts of interest that may be exist in our businesses. These include: a) Conflicts principally resulting from the fact that we are a director member of a company Group in which a member of that Group (whom we wish to investcall an “Affiliate”) may have a financial or other business interest in the trades we do for you. 29.2.5 b) Conflicts principally resulting from the fact that we provide investment services to other clients. c) Conflicts principally resulting from the fact that we or an Affiliate, or third party service provider or an employee may also be trading in conducting our business, our directors, officers or employees may learn confidential information about the same securities as we trade for our clients, prospective clients and third parties. 29.2.6 directors, officers or employees may be offered hospitality or gifts by service and product providers. 29.3 to manage any potential conflict we operate a number of polices and procedures as follows: 29.3.1 we have implemented a policy of independence with which our directors, officers and employees are required to disregard any information they receive or action they have taken d) More specifically in relation to one client when dealing with another. 29.3.2 we do not distribute investment research. 29.3.3 if one our services, (as opposed to the rest of our directorsGroup): i. we may act for other clients and may conduct conflicting trading strategies for different clients. In particular, officers you may have acted upon advice from us to sell assets to fund a particular investment strategy, but the same assets may be purchased within the DMPS, if investment managers deem that they are suitable. Likewise, investments may be sold without regard to whether they have been recently acquired; ii. we may act as the manager of the assets attributable to any insurance policy or employees is a director policies held for your benefit; iii. we may sell certain securities from within the DMPS because they no longer qualify for portfolios that may be subject to different regulations (including ISA regulations or HMRC pension regulations) but which are managed or administered using the same trading platform as the DMPS; iv. we may act as principal to transactions conducted on your behalf (but only where we act as trustee of a company personal pension scheme); v. we may act as your Adviser and, contemporaneously, act in which we wish to invest we will not invest in this company on a pro-active basis on behalf fiduciary capacity as trustee of discretionary clients. 29.3.4 your Assets and as investment manager for you. Some of the measures we have Personal Account Dealing procedures adopted to ensure that manage identified conflicts are set out below. We consider them appropriate to our efforts to take reasonable care that, in relation to each identified conflict, we do not compromise our dealing arrangements for clientsact independently to avoid material risk of damage to your interests. 29.3.5 our directors, officers and employees are required to disclose and in all cases must obtain approval from us before carrying out any outside business interest or employment. 29.3.6 our directors, officers and employees are required to maintain Confidentiality of all information entrusted to them, except where disclosure is required by law or authorised by you. Further, directors, officers and employees are not permitted to use such information for their personal gain. 29.3.7 corporate hospitality and gifts must be approved before they may be accepted or given. Any gifts received by individuals or the firm are put into a lottery in which all staff take part. 29.4 Status of this Policy: This policy does not form part of our Terms of Business, is not intended to be contractually binding or impose or seek to impose any obligations on us which we would not otherwise have whether under our Terms of Business or the FCA Rules had this policy not been disclosed to you. 29.5 A summary outlining SEI's policy with regard to Conflicts of Interest is available on request.