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SKY Harbor Capital Management

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.

SKY Harbor recognizes that potential conflicts of interest may arise in conducting the business of an investment manager, and has clearly stated compliance policies and procedures designed to address potential conflict that may arise. Such policies and procedures include, but are not limited to, side-by-side management, trade allocation, brokerage practices and asset valuation and liquidity determinations. Operationally, systems and risk controls have been constructed to identify possible conflicts, which if detected, are escalated to the Chief Compliance Officer and Chief Risk Officer for appropriate mitigation. Conflicts of interest in personal trading are mitigated by the firm’s Code of Ethics, which does not permit employees to purchase any securities (even the equity securities) of an issuer whose below-investment-grade debt securities have been purchased by the firm for client portfolios. SKY Harbor’s Conflicts of Interest Policy is stated in our Compliance Manual and SKY Harbor conflicts of interest are disclosed in the Part 2A of the Firm’s Form ADV filed with the SEC.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)