Conflicts of Interest Policy
In all business, conflicts of interest may arise. We have a regulatory requirement to identify and manage such conflicts and, where that is not possible, to make disclosure of them and mitigate them. Our Risk and Compliance team are in charge of this process but every member of CAM is responsible for identifying conflicts in their day-to-day work and receives regular training on the topic. All staff must disclose any outside interests that may create a conflict with their ability to provide good service to our clients or perform their regulated functions.
Conflicts may arise in many ways. The conflict may be between a client and CAM, between an employee and a client, or between two different clients. There may also be a conflict between CAM’s interests and those of our custodian and administrator, Platform Securities LLP (‘PSL’) or between other third parties with whom we interact, such as fund managers or advisers. In all cases, it is our job to ensure that the potential conflict is managed and that there are controls in place so that it does not result in any detriment to our clients. We take this responsibility very seriously and it is reflected in many aspects of our work, always ensuring that our clients are able to receive good outcomes from our service.
Regarding the service that Platform Securities provides, you can access full details of their approach to conflicts at https://discover.fisglobal.com/platform-securities.html.
The Risk and Compliance Department maintains a Conflicts Register and all employees regularly update this as the need arises. The Department also holds information on all personal account dealing and logs any hospitality or receipt or donation of a gift that may potentially be an inducement. There are clear procedures on personal account dealing, for example: prohibiting employees for trading ahead of clients, and gifts and hospitality, including attending events paid for by third parties. These procedures and rules are regularly updated to ensure they reflect best practice in our industry. This allows us to ensure that all individuals and teams are prioritising the needs of our clients and are not influenced unduly by a third party. Reporting to the Executive Committee and the Board across all of these areas takes place frequently. This procedural approach is intended to support our strong culture of focusing on our clients’ needs.
Other forms of conflict are managed in accordance with our Insider Dealing policy, focusing on ensuring that information that is not publicly available is properly handled. Our Privacy Policy also supports the management of conflicts by ensuring that we keep clients’ information confidential. Our Board is responsible for setting remuneration and we maintain a Remuneration Policy that we believe reflects best industry practices. Our remuneration and bonus schemes are in place to ensure that our employees remain motivated, whilst also ensuring that the schemes do not encourage inappropriate behaviour, such as excessive trading. We continually monitor all aspects of our business that may, potentially, be subject to abuse.
The Risk and Compliance team maintain a list of all conflicts and are always glad to discuss any issue that may concern you.
Version February 2023