Purpose

In accordance with the applicable regulatory requirements, CSAM has drawn up and maintains in operation a written, effective policy for managing conflicts of interest that is appropriate for its size and organisation and the nature, importance, and complexity of its business activities.

This policy helps prevent, identify, and deal with conflicts of interest to avoid their harming the interests of clients and unitholders/shareholders, thereby avoiding any reputational risk.

Definitions and goals

Definitions

A conflict of interest is a situation that entails having to choose:

In particular, Article 30 of the AIFM Delegated Regulation and Article 33 of Delegated Regulation 2017/565 (MiFID II) define potential conflict of interest situations, such as situations where CSAM (or a person tied to it):

Goals

Prevention

Prevention of the arising of conflicts of interest by educating all staff in the internal and external rules and codes of conduct, and by implementing strict rules and procedures