The rules adopted by the Company for dealing with conflicts of interest are based on the following 4 pillars:
1. Duty of identification: the Company has identified the conflicts of interest that may have a negative effect on its clients’ interests;
2. Duty of organization: the Company has organized itself in such a way as to neutralize the possible negative effects of conflicts of interest;
3. Duty of disclosure: if the Company considers that the organizational measures adopted to manage certain cases of conflicts of interest are not able to ensure the prevention of losses to clients, it informs the clients clearly, before acting on their behalf, of the nature and sources of the conflict of interest, so that they can take an informed decision on the service provided. With regard to the UCIs managed, if the aforesaid circumstances arise, the administrative body takes the necessary decisions to ensure fair treatment for the UCIs themselves and the members thereof;
4. Duty to act honestly and fairly: in providing the portfolio management service, the Company acts correctly, fairly and professionally to best serve its clients’ interests.