Introduction

It is a fundamental requirement for a financial services firm to identify and manage conflicts of interest. This is central to the duty of care we owe to our clients. The Asset Management Exchange (AMX) will take all appropriate steps to identify conflicts, manage them effectively and to treat our clients fairly. This document seeks to provide a high level description of how conflicts of interest can arise in our business and how they are managed. AMX has numerous controls, policies and procedures in place to ensure that we manage conflicts when providing services or products to clients. Employees, directors and non-executive directors of entities within AMX are required to follow them.

What conflicts could arise

A conflict of interest may arise where competing obligations or motivations may damage the interests of a client. In identifying the conflicts of interest that may arise when providing services to clients, we will take into account the following:

• Client versus client conflict – where we may be unable to act in the best interests of one client without adversely affecting the interests of another client.
• Firm versus Client conflict (including Client/third party conflicts) – our own corporate interests conflict with a duty we have to a client, in certain instances where that ability to act in the best interest of the client is impacted by our relationship with a third party.
• Intra-group conflict – where the interests of an AMX corporate entity, director, employee or fund thereof conflict with the interests of another AMX corporate entity, director, employee or fund thereof.
• Individual versus client conflict – an employee’s personal interest does or could conflict with
  a duty we have to a client.

How are conflicts managed?

We are required to maintain and operate effective organisational and administrative arrangements with a view to taking all appropriate steps to prevent conflicts of interest from constituting or giving rise to a risk of damage to the interests of its clients.

We have a strong culture of managing conflicts of interests in AMX and this is supported by a number of processes and policies. We provide all staff with training on awareness and understanding of how conflicts could arise within our business.

There are a number of groupwide policies and procedures designed to ensure that every employee in the business is personally responsible for highlighting and managing conflicts of interest. These policies ensure that once a conflict has been identified, it is managed in a way that gives reasonable assurance
that there is no material risk of damage to the interests of clients.

Steps taken by AMX to manage actual and potential conflicts include the following:

1. Effective procedures to prevent or control the exchange of information between relevant
   persons engaged in activities involving a risk of a conflict of interest where the exchange of that
   information may harm the interests of one or more clients.
2. The separate supervision of relevant persons whose principal functions involve carrying out
   activities on behalf of, or providing services to, clients whose interests may conflict, or who
   otherwise represent different interests that may conflict.
3. The removal of any direct link between the remuneration of relevant persons principally
   engaged in one activity and the remuneration of, or revenues generated by, different relevant
   persons principally engaged in another activity, where a conflict of interest may arise in relation
   to those activities.
4. Measures to prevent or control the simultaneous or sequential involvement of a relevant person
   in separate investment or ancillary services or activities where such involvement may impair the
   proper management of conflicts of interest.
5. Reporting lines which limit or prevent any person from exercising inappropriate influence over
   the way in which a relevant person carries out investment or ancillary services or activities.
6. As required by our Code of Conduct, all employees are required to
   identify and disclose any personal associations that may give rise to an actual or perceived
   conflict of interest.
7. Internal guidance and training on the identification of possible issues of conflict as they arise.
8. Escalation procedures which ensure that issues identified are referred to and considered at the
   appropriate level; and
9. Other relevant policies and procedures, including the personal account dealing requirements in
   the Code of Conduct, the Gifts and Hospitality Policy and the Anti-Bribery and Corruption
   Policy.

Disclosure

Conflicts and potential conflicts of interest are reviewed regularly and where it is not possible to manage an actual or potential conflict satisfactorily we will disclose this to you.