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Breckinridge Capital Advisors

PRI reporting framework 2017

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage (Not Completed)

SG 02. Publicly available RI policy or guidance documents (Not Completed)

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Management of conflicts of interest are covered in several policies and procedures, most notably in our Code of Ethics, Proxy Voting Policy and Allocation Policy. We expect employees to adhere to the highest standards of ethical conduct and to act in our clients’ best interests. Employees are expected to disclose any potential conflicts of interest with clients, including personal activities that could cause such conflicts. Generally, employees are not permitted to invest in securities that would be eligible for client portfolios, nor are they permitted to invest in any of the company's strategies. Although Breckinridge does not regularly receive proxy ballots for fixed income securities, the firm has a policy to vote proxies in the best interest of the shareholder. Additionally, when allocating investment opportunities, we seek to treat all clients in a fair and equitable manner. To the extent that the amount of bonds is insufficient to fill the entire inquiry, priority of the client portfolios will generally be chronological, with those that were in the queue first receiving allocations.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)