It is the policy of SSGA to treat all client accounts fairly and equitably. A variety of mechanisms are employed that are designed to manage conflicts of interest. This includes the effective management of potential or actual conflicts of interest. The following mechanisms and practices are used by SSGA:
- Providing appropriate disclosure in a reasonable and timely manner of actual and potential material conflicts of interest;
- Taking steps to minimize the effect of any material conflict of interest on any client’s account;
- Implementing appropriate policies, procedures and controls;
- Managing each client’s account in accordance with client-identified guidelines and restrictions;
- Monitoring for compliance with those policies, procedures and controls;
- Making reasonable efforts to ensure that no client or categories of clients are inappropriately advantaged at the expense of another client and;
- Reporting and/or escalating identified conflicts of interest situations that need to be addressed.