Potential conflicts of interest may arise from time to time in connection with mandates managed by GAM. In accordance with applicable rules, GAM seeks to manage such conflicts of interest fairly. As a fiduciary, GAM allocates investment opportunities among clients in a fair and equitable manner. In allocating securities among clients, it is GAM’s policy that all clients should be treated fairly and that, to the extent possible, all clients receive equivalent treatment.
GAM has group-wide (and locally implemented) procedures relating to inside information, including, without limitation, prohibitions around its use, restrictions around its maintenance and general reporting obligations. GAM monitors trading in affected securities across GAM portfolios and personal account dealing during the period within which information continues to retain the status of inside information.