As a portfolio management company, Committed Advisors shall take all reasonable measures ensuring the detection of conflicts of interest situations in the context of the provision of investment advisory services or the management of its funds.
Conflicts of Interest Policy
“Relevant Persons” are defined as Committed Advisors’ executive officers, employees as well as any individual participating, under the authority of Committed Advisors and/or pursuant to an outsourcing agreement, in the provision of investment advisory services or management of the funds managed by Committed Advisors.
Conflicts of interests may arise either between Committed Advisors, the Relevant Persons or any person directly or indirectly related to Committed Advisors, on the one hand, and Committed Advisors’ clients, on the other hand; or between two of Committed Advisors’s clients.
For example, a situation of conflict of interest appears where:
— Committed Advisors or a Relevant Person might receive a financial gain or avoid a financial loss at a client’s expense;
— Committed Advisors or a Relevant Person has an interest in the outcome of a service provided to the client or in a transaction carried out on behalf of the client that differs from the client’s interest;
— Committed Advisors or a Relevant Person is induced, financially or otherwise, to favor the interest of a client or group of clients over the interests of the client to whom the service is provided;
— Committed Advisors or a Relevant Person receives or will receive from a person other than the client an inducement in relation to the service provided to the client, in any form whatsoever, other than the commission or fees normally charged for this service.
Any Relevant Person who identifies a risk of conflict of interests, whether potential or actual, or who has questions about a situation likely to generate a conflict of interests, shall immediately inform the Chief Compliance Officer (CCO). Such notification shall be made via any sustainable medium (email, internal memo…).
The notification should include:
— The services concerned;
— The date on which the conflict of interest was noted;
— The actual or potential nature of the conflict of interest;
— A description of the conflict of interest;
— The clients impacted by the conflict;
— The possible impact on relevant clients.
MANAGEMENT OF CONFLICTS OF INTEREST
The CCO is responsible for the management of reported conflicts of interests. The CCO’s opinion in response shall be recorded in writing in the repository of conflicts of interest and notified to the Relevant Person, with a copy sent to Committed Advisors’ managing partners.
The CCO reviews the nature, causes and consequences of the identified conflict of interests, and takes all appropriate measures to limit the immediate consequences thereof. If the conflict of interest is already addressed in the « Register of Conflicts of Interest », the CCO implements a solution in accordance therewith. If the implementation of measures and procedures does not ensure the required degree of independence, the CCO takes all additional or alternative measures as may be necessary.
The CCO implements any corrective measure to avoid or limit the occurrence of the identified conflict of interests, including by amending or adopting necessary measures and/or by reinforcing controls if possible.
Where the measures adopted by the CCO are not sufficient to guarantee, with a reasonable certainty, that the risk of infringement of the clients’ interests can be avoided, Committed Advisors shall inform the relevant client or clients of the general nature or source of the conflicts of interests. A copy of the letter sent to the client shall be recorded in the repository of conflicts of interest.