Comgest has implemented rules, policies and procedures in order to mitigate the risk of conflict of interest:
The Compliance Officer prior approval is needed.
The request won’t be approved if an order has been executed on the relevant security on behalf of a portfolio managed within the last two days or if an order is currently been executed or planed for execution for the two following days.
The cash of the company is managed independently from portfolio managers and is not invested in listed shares.
Orders are pre-allocated and the system used does not allow ex-post changes.
Group orders must be allocated on a prorata basis in case of partial execution.
Any different allocation must be justified in the system and must be in the interest of the relevant investors.
Best execution and best selection policies have been implemented.
As an independent company, Comgest has no ownership or capital link with any broker or counterparty. Therefore, brokers and counterparties are exclusively chosen in the best interest of investors.
Despite these rules, policies and procedures, if a conflict of interest occurs, Comgest will manage it in the interest of the investors and will inform the relevant investors.