The Conflicts of Interest Policy of Pathfinder Asset Management Pte. Ltd. (the “Company”) is designed to identify, assess, manage and if appropriate, disclose all potential and actual conflicts of interest in the Company’s business.
The Company will manage conflicts of interest fairly, both between the Company and its clients as well as between one client and another client.
The Company will take all reasonable steps to identify conflicts of interest between:
• the Company (including its directors and managers) and a client of the Company; or
• one client of the Company and another client.
Types of Conflict
The Company undertakes asset management services on behalf of multiple clients.
For the purposes of identifying the types of conflict and potential conflicts that arise which may entail a material risk of damage to the interests of a client, the Company will take into account whether the Company (including its directors and managers):
• is likely to make a financial gain, or avoid a financial loss, at the expense of the client
• has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client; or
• receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services other than the standard commission or fee for that service.
Managing Conflicts
Governance
The Company has governance arrangements and management oversight of the business. Key business decisions are taken by the Board who understand the Company’s obligations to manage and mitigate conflicts of interest.
The Compliance Officer is tasked with identifying conflicts of interest and reports directly to the Board. Management information relevant to identifying conflicts is reviewed by the Compliance Officer.
This Policy will be reviewed annually by the Board.
Mitigating Controls
As the Company will be managing clients’ assets, there may be potential conflicts of interest when the Company, or its directors and managers, are investing in the same instrument. To mitigate any potential conflicts, clients’ allocation will always be filled first. There will be no selling or buying of investments between the Company (including its directors and managers) and a client.
Personal Conflicts
Directors and managers are required to disclose in writing any conflicts of interest upon commencement of employment with the Company and on a periodic basis. Directors and managers will disclose any conflicts of interest directly to the Compliance Officer and, if necessary, to the Board.
A Director or manager of the Company cannot buy or sell investments to a client of the Company.
To mitigate any potential conflicts, a Director or manager of the Company must hold personal investments for a minimum period of six months.
Disclosure to Clients
The Company will disclose to its clients all material conflicts in sufficient detail so as to allow the client to take an informed decision in relation to the service offered.
If the Company’s arrangements to manage a potential conflict of interest are not sufficient to ensure with reasonable confidence that the risk of damage to that client’s interests is prevented, the Company will inform the client in writing or on the Company’s website.
1 June 2024