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:

• between the interest of CSAM and the interest of the client/unitholder/shareholder
• between the interest of the client/unitholder/shareholder and the interest of another client/unitholder/shareholder
• between the interest of CSAM and the personal interest of an employee
• between the interest of the client/unitholder/shareholder and the personal interest of an employee
• between the interest of CSAM’s shareholders and those of its clients/unitholders.

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):

• may earn a financial profit or avoid a financial loss at the client’s expense
• has an interest in the result of a service provided to the client or a transaction performed on the client’s behalf that differs from the client’s interest in this result
• is led, for financial or other reasons, to privilege the interests of another client or group of clients over the interests of the client to whom the service is being provided
• exercises the same professional activity as the client
• receives or will receive from a person other than the client a benefit of any kind whatsoever in relation to the service provided to the client, other than the fee or expenses normally charged for such a service.

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