Conflicts of interest policy

Introduction

Gresham House Asset Management Ireland Limited is authorised as an Alternative Investment Fund Manager and is regulated by the Central Bank of Ireland. Its authorisation allows it to provide a range of services to retail and fund clients. This document is not intended to provide a comprehensive account of the controls and procedures in place to manage all conflicts of interest (“conflicts”) which may arise. It is intended to outline the main controls in place. Gresham House Asset Management Ireland Limited is committed at all times to ensuring that our business is conducted to high standards and in an ethical manner.

Identification of conflicts of interest

As Gresham House Asset Management Ireland Limited offers financial services, it is possible that a number of potential or actual conflicts may arise. This means that from time-to-time Gresham House Asset Management Ireland Limited may have interests which conflict with our client’s interests or with duties that we owe our clients. This includes conflicts arising between the interests of Gresham House Asset Management Ireland Limited, other entities within the wider Gresham House group and employees on the one hand and the interests of our clients on the other and also conflicts between themselves.

When we enter into a transaction for you, we, or one of our group companies could be:

• buying or selling units in a collective investment scheme where we are, or a group company is, the manager of the scheme;
• buying investments where we are, or an associated group company is, involved in a new issue, rights issue, take-over or similar transaction to do with the security;
• involved in business relationships with the company or a related entity in relation to the investment concerned;

Procedures to manage conflicts of interest

Gresham House Asset Management Ireland Limited uses administrative and organisational arrangements to ensure that our employees act independently and, in a manner, designed to safeguard the interests of our clients. These arrangements include:

• procedures to prevent or control the flow of information within Gresham House Asset Management Ireland Limited and the wider group in order to protect client interests and to prevent improper access to client and market information;
• having in place independent reporting lines for the segregation of duties (information walls);
• arms-length management of intra-group relationships;
• rules and procedures in place governing personal account dealing;
• Compliance with Best Execution Policy and order allocation rules;
• a Remuneration Policy is in place in accordance with relevant regulatory requirements;
• staff being subject to the Gifts and Entertainment Policy;
• controls in place to identify and manage cross board directorships, outside business interests and personal connections; and
• regular training of all employees on internal rules in respect of conflicts and obligations to act in the best interest of clients.

Gresham House Asset Management Ireland Limited monitors compliance with our conflicts policy and related procedures. Should you have further queries as to how Gresham House Asset Management Ireland Limited manages conflicts of interest please reach out to your Gresham House Asset Management Ireland Limited contact.