Carnegie Fonder has adopted policies and procedures designed to identify and manage conflicts of interest. Both Carnegie Fonder and its employees shall act in the best interest of its customers.
Employees should be alert to potential conflicts of interest and, if such occurs, ensure they are handled with integrity and honesty. Carnegie Fonder’s interests should never be put before the interests of customers and no customer should be favored at the expense of another.
Areas where conflicts of interest do or may exist are reviewed regularly. Carnegie Fonder has a number of procedures for managing conflicts of interest which are monitored by second line of defense. As an example, the grandfather principle is applied to internal procedures.
Furthermore, information is limited to employees who need it to perform their work. Personal account dealing is closely monitored in accordance with regulatory requirements.
The board and management are informed of significant conflicts of interest.