The overriding principle is that 3i will treat its customers fairly and will not place the interests of one customer above those of another, or its own interests above those of its customers.
3i acts at all times in accordance with the relevant regulated 3i entity’s fiduciary position as manager, and applicable FCA/SEC principles and rules around treatment of regulatory customers. 3i will also at all times comply with applicable legal and regulatory requirements.
Set out below are the steps taken to manage a conflict. Appropriate records of the consideration of conflicts will be kept at all stages
- Conflict of interest identified and information barriers put up as necessary
- Relevant 3i leadership group member(s) and Group Compliance consider and resolve the conflict, or refer it to the 3i Conflicts Committee if necessary
- 3i Conflicts Committee acts in a consultative role, advising on how to manage the conflict
- Where 3i is unable to resolve a conflict fairly, clear disclosure of the conflict will be made to the relevant customer(s) to enable them to take an informed decision. 3i will seek to resolve the conflict in collaboration with the customer(s).
There is a permanent information barrier in operation around 3i Debt Management.