The key elements of Maple-Brown Abbott’s conflicts management process as it relates to the investment process are as follows:
Representatives are remunerated by salary and performance related bonuses and do not receive a commission for providing any financial service.
The Code of Ethics (CofE) contains a section on Conflicts of Interest. All dealings by employees must be in accordance with the CofE, and all staff annually attest compliance with this policy:
- obtain prior approval for all personal securities transactions from an executive director;
- not deal in any stock where there is an uncompleted order in the market for any portfolio;
- maintain a record of personal securities transactions (Register); and
- make an annual declaration as to their personal securities transactions.
- Compliance keeps copies of each employee’s Register. The Register is reviewed annually by the Managing Director.
Investment analysts are not permitted to trade a security on which they are preparing a new research report.
Any breaches of the CofE must be:
- reported to a manager, the Head of Regulatory Compliance and Risk or to the COO; and
- recorded in the Company’s Breach Register, which is tabled before the Audit and Compliance Committee (A&CC) every quarter and before the Board every year.