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Conflict of Interest

Introduction

This policy is issued pursuant to, and reflects compliance with, the European Directive 2004/39/EC of 21 April 2004 on markets in financial instruments (MiFID) and with the implementing Danish legislation BEK nr 428 af  09/05/2007 §16  (the “Rules”) that applies to Global Evolution Fondsmæglerselskab A/S and subsidiaries  (the “Company”). It is not intended to create third party rights or duties that would not already exist if the policy had not been made available and it does not form part of any contract between the Company and any client or prospective client.

This Policy is a specification of the company’s general obligation to act with integrity and fairness, towards its clients as well as its counterparties when delivering investment management and other services to clients.

The Company is committed to professionally managing potential conflicts of interest which may arise between its constituent businesses. The policy is available to clients upon request.

Identification and general disclosure of the nature of potential conflicts of interest

The Company hereby identifies and discloses a range of circumstances which may give rise to a conflict of interest and potentially but not necessarily be detrimental to the interests of one or more clients. Such a conflict of interest may arise if the Company, or any client, shareholder, board member, employees, significant suppliers or business partners or other party directly or indirectly related to the Company or a client, is likely to make a financial gain, or avoid a financial loss, at the expense of another party. The Company will always consider the client’s best interest so that any conflict of interest is managed fairly.

The Company has identified the following circumstances which may give rise to a conflict of interest:

1.     The Company may provide advice to clients whose interests may be in conflict or competition with other clients’ interests;

2.     The Company, its employees and related legal persons may have, establish, change or cease to have positions in securities, foreign exchange or other financial instruments covered by investment services provided to clients;

3.     The Company manages client accounts/funds with different fee structures, including some with significant performance fee elements;

4.     The Company may receive or pay inducements to or from third parties due to the referral of new clients.

5.     The Company may select counterparties for specific trades based on the ability and willingness of the counterparties’ analysts to provide meaningful research material, which would benefit the Company in terms of reduced research costs.

There are no specific circumstances identified that may lead to conflicts of interest as a consequence of the structure and/or business activities between various group companies.

Managing Conflicts of Interest

In order to manage possible conflicts of interest, the Company maintains processes, procedures and organizational arrangements, which are referred to hereinafter.

Critical arrangements for managing conflicts of interest include the following:

1.     All employees are bound by professional secrecy, and confidential information is only to be shared if essential for performing a job function;

2.     All employees are at all times bound to act loyally to the Company and be in full compliance with its procedures;

3.     All employees receive instructions and guidance regarding managing of conflicts of interest;

4.     All clients are to be treated fairly;

5.     All employees are bound by the Company’s rules and guidelines for personal securities trading as in force and effect from time to time;

6.     All representatives of the company hold a license if a license is required for performing the business in the country where the representative is registered;

7.     The company has procedures in place for and monitors the giving and receiving of entertainment and gifts.

8.     The company monitors internal reporting and the effectiveness of its policies and procedures for managing conflicts of interest.

Monitoring and review of the Policy

The effectiveness and accuracy of this Policy, the Company’s compliance in acting in accordance with it and the principles and procedures contained in it will be monitored on a continuous basis by the Company. Monitoring will be aimed at assessing on a continuous basis the execution quality of the brokers used pursuant to this Policy. Monitoring will include reporting of any identified conflict of interest to the Chief Executive Officer and Compliance. Compliance will maintain a register of actual conflicts of interest occurred that can be detrimental to the interests of one or more clients.

The policy will be subject to an annual review.