Version 1.0, valid from 15. september 2022
Fundvest avoids conflicts of interest and takes all necessary measures to identify and manage conflicts of interest between Fundvest as an organisation, its management, employees, tied agents, and other persons directly or indirectly linked to Fundvest (the Relevant persons) and its Clients or solely between the Clients, where conflicts of interest arise in the provision of investment services, ancillary services or a combination thereof.
Fundvest applies the below-listed measures to prevent and manage conflicts of interest:
Screening. Relevant persons are required to declare their personal interests and to report relationships that may be related to a potential conflict of interest.
Right to withdraw. Fundvest has the right to decline or withdraw from a transaction in which a significantly material conflict of interest may arise.
Insider trading prohibition. Relevant persons are prohibited from misusing material and nonpublic information for their personal interests.
Chinese walls. The exchange of information between different roles and units is restricted to eliminate the misuse of confidential information.
Fair treatment of clients. The Company is committed to treating its Clients fairly.
Other. Relevant persons are regularly trained to be able to identify a potential conflict of interest and take necessary actions. Conflicts of interest that were identified are registered and investigated by dedicated personnel. Fundvest reviews and improves its internal control system on an ongoing basis.
When the measures taken by Fundvest to avoid or manage a conflict of interest are not sufficient to ensure that risks of damage are prevented, Fundvest discloses conflicts of interest to the Client or other affected parties.