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Conflicts of Interest Policy

Introduction

In accordance with our commitment and obligations to our clients, Absolute Return Partners LLP (ARP) seek to ensure that our clients are properly treated where there are or could possibly be conflicts of interest. Conflicts of interest may arise between ARP and one of its clients or between one client of ARP and another client. ARP’s failure to act in the best interests of a client may involve a material risk of damage to the interests of that client. We therefore take our responsibilities in this regard very seriously. In the following, we set out our policy for avoiding conflicts of interest.

What conflicts of interest could arise?

The nature of the financial services industry is such that conflicts of interest can sometimes develop. Generally, a conflict of interest arises where the interests of the financial services company and its associates are different from its client or clients. For example, where ARP discharges its duty to one client it might create a conflict with another client.

How are conflicts managed?

Our Conflicts of Interest Policy identifies the types of conflicts we face and the controls we have put in place to mitigate those conflicts. The policy is reviewed regularly to ensure the record of conflicts is up-to-date and relevant and the appropriate mitigating controls are in place.

ARP has implemented procedures and controls and segregations of duties. Staff are segregated operationally, such that they report to functional managers and each have distinct password protected IT access.

ARP also has specific policies and procedures on when and how employees are permitted to undertake personal account transactions, restrictions on the offering and receipt of gifts to or from clients and other businesses counterparties. We also monitor our staff’s external interests to ensure they do not conflict with their duties to ARP and its clients.

Finally, our remuneration policy is designed to ensure that remuneration structures do not create conflicts of interest between members of staff and our clients.

Any client may request a full Conflicts of Interest Policy.