IDENTIFICATION OF POTENTIAL CONFLICTS OF INTEREST. To adequately manage conflicts of interest, the Company shall identify all relevant conflicts timeously. Xxxxxx Capital Seychelles Limited will employ different mechanisms to ensure that all conflicts are identified. The Company shall identify all conflicts of interest, their severity and document controls to mitigate the conflicts. It is not possible to list all situations which could constitute a conflict. The facts of each situation will determine whether the interest in question is such as to bring it within the area of potential conflict. All employees, including management, will be responsible for identifying specific instances of conflict and required to notify the Compliance function of any conflicts they become aware of. The Compliance Officer (CO) will assess the implications of the conflict and how the conflict should be managed in conjunction with the board. For the purposes of identifying the types of conflicts of interest that arise in the course of providing investment and ancillary services or a combination thereof and whose existence may damage the interests of a client, the Company takes into account, by way of minimum criteria, the question of whether the Company or a relevant person, or a person directly or indirectly linked by control to the Company, is in any of the following situations, whether as a result of providing investment or ancillary services or investment activities: The Company or a relevant person is likely to make a financial gain, or avoid a financial loss, at the expense of the client; The Company or a relevant person has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client's interest in that outcome; The Company or a relevant person has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client; The Company or a relevant person carries on the same business as the client; The Company or a relevant person receives or will receive from a person other than the client, an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service; For the purpose of this Policy, a “relevant person”, in relation to the Company means any of the following: a director, partner or equivalent, manager, or tied agent of the Company; a director, partner or equivalent, o...
