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Conflict of Interest Policy

THEAM's Conflict of Interest Policy

As an asset management company, THEAM may encounter situations of conflict of interest in the normal exercise of its activities. However, THEAM has the ability to manage such conflicts of interest, whether actual or potential, in a manner that avoids deriving undue advantage from such situations and any breach of its obligations to its clients or the obligation to comply with applicable laws and regulations.

A conflict of interest is a situation in which the interests of THEAM and/or those of its clients and/or employees come into conflict in the course of doing business, whether directly or indirectly.

 

THEAM’s conflict of interest policy is based on:

  • the identification of potential conflicts;
  • the promotion of rules or procedures designed to prevent such conflicts or manage them;
  • the formulation and implementation of such procedures;
  • the creation of a register;
  • implementation of the modalities for disclosure to clients when conflicts of interest cannot be overcome;
  • the creation of a framework in which to address as yet unidentified situations of conflict of interest during the stages mentioned above;
  • employee awareness and training.

 

To address a conflict of interest, THEAM (or its employees) may:

  • abstain from taking action if the situation carries a particularly critical risk;
  • accept the conflict of interest but prevent any significant undue advantage arising out of the situation and protect the customer through the introduction of permanent structures designed to manage most situations of conflict of interest in an appropriate manner once such situations are recognised.
  • when the situation cannot be adequately addressed by the foregoing provisions, disclose the conflict of interest or obtain a waiver or appropriate consent from the client with the understanding that disclosure does not release THEAM from its obligation to control conflict of interest situations to prevent undue advantage and to protect the client.

 

Given the fiduciary nature of the portfolio management services that it provides, THEAM places great importance on identifying, preventing and managing any conflicts of interest that may arise.

The arbitrage of conflict of interests are compliance duty. If a conflict is not solved at local level, it has to be addressed to the head of Compliance for BNP Paribas Investment Partners France. The monitoring of ethics and operational procedures is ensured by different levels of the organisation such as the operational teams, the hierarchy, the head of Compliance and the Group internal audit function.

Investments in the aforementioned fund are subject to market fluctuation and risks inherent in investing in securities. The value of investments and the revenue they generate can increase or decrease and it is possible that investors will not recover their initial investment. Source: BNP Paribas Investment Partners.