Conflicts of Interest Policy
Introduction
Levendi Investment Management Limited (“Levendi”) maintains and operates effective organisational and business arrangements taking all reasonable steps to identify, monitor and manage conflicts of interest. At Levendi Investment Management we conduct our business activities honestly and with integrity. This policy comprises of a list of criteria which help to identify potential conflicts of interest.
This policy does not create any third-party rights or duties and does not form part of any contract between Levendi Investment Management and any other party.
Identifying the Conflicts
A conflict of interest may arise where a company, or one of its employees, is providing a financial service to its clients and may, as a consequence of its actions, introduce a material risk of damage/loss to a client’s interests. When identifying the types of conflict of interest which may arise, we taken into account whether Levendi Investment Management or an employee:
- is likely to make a profit or avoid a loss at the expense of a client;
- has an interest in the outcome of a service to the client;
- has a financial or other incentive to favour the interest of another client;
- could be in a position where its ability to act in a client’s best interests is potentially affected by another matter.
Methods of Managing Conflicts
Levendi Investment Management actively manages such conflicts of interest in order to minimise the risk of damage/loss to its clients and deals with conflicts effectively and fairly. Management of such risks is achieved by one or more of the following:
- Ethical Walls – where information held by a person in one part of the business is withheld from personnel in other business activities;
- Removal of direct remuneration links for employees;
- Promoting a culture of integrity;
- Gifts / Hospitality and Inducements – are all issues that could lead to potential conflicts of interest.
Employees of Levendi Investment Management must not solicit or accept any inducements which may conflict with our obligations to clients. Employees will not accept any gifts other than those considered normal in their line of business and must be recorded within the DCA register. Excessive gifts may result in a conflict of interest. For all gifts worth over £75 a Director must opine upon it’s appropriateness and acceptability.
Levendi Investment Management has a clear policy on Conflicts of Interest:
Conflicts of Interest should always be avoided, wherever possible.
Conflicts or potential Conflicts of Interest must always be disclosed by employees to Thornbridge Investment Management LLP.
In the unlikely event that Levendi Investment Management is unable to manage or avoid a conflict of interest; we will disclose the conflict prior to conducting further business with the relevant clients.
