The Firm must take all reasonable steps to ensure that conflicts of interest between itself and its clients, between its Employees and clients and between one client and another are identified and then prevented or managed, or disclosed, in such a way that the interests of a client are not adversely affected. It is the Firm’s policy that we should, to the extent possible, aim to avoid conflicts of interest. However, at times, conflicts of interest cannot be avoided and may arise in any area of our business, between employees and the Firm, between employees and the Client or between the Firm and its clients and sometimes between clients. The determining factor in such potential conflicts of interest is the likelihood of an employee or the Firm making a financial gain (or avoiding a loss) at our clients’ or the Firm’s expense.

To manage potential or actual conflicts of interests, it is imperative that the confidentiality of client and the Firm data is maintained and that employees do not disclose or use this data inappropriately. Directors, employees and where relevant contractors must advise the CO of any potential or actual conflicts of interest. The following information is to be included in the notification:
● names of the client or clients concerned;
● nature of the conflict; and
● whether the conflict is deemed to be an actual conflict or a potential conflict;

The CO will review the notification and where required escalate it for consideration and action to the CEO or in case of an issue relating to the CEO or a major conflict, to the Board. Either the CO, the CEO or the Board (depending on who is independent and not party to the conflict) will determine the best way to address the conflict of interest, or perceived conflict of interest. If it is not possible to remove the conflict, or where the measures in place do not sufficiently protect a client’s interests, the Firm will disclose the conflict to the client. The Firm may also decline to act for a client in cases where the conflict of interest cannot be managed in any other way. Where such a situation arises, the decision will be made by the CEO. In cases where the conflict relates to the CEO, a written decision by a member of the Board is required. The Board reviews and approves our conflicts of interest policy. Internal auditors, as part of their annual audit, also review a sample of transactions to ensure that conflict notification, escalation, resolution and reporting are working as stated and any deficiencies are highlighted in the report which is submitted to the Board for comments and action.