The Board has a policy and effective procedures for managing and, where appropriate, approving conflicts or potential conflicts of interest.
An example of one our policies is the removal of any direct link between the remuneration of persons principally engaged in one activity and the remuneration of, or revenues generated by, different persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities.
Where there is a conflict that in our view cannot be readily resolved, the matter would be escalated to senior management for an independent decision on whether and how such shares should be voted.
A Register of Conflicts is held by the Compliance department and a log of all conflicts raised is maintained and updated accordingly. Our policy summary regarding conflicts of interest is regularly reviewed and any changes are approved by the relevant Committee. It is set out in Our Services and Business Terms and available on our website.