Insight ensures it manages conflicts of interest fairly and in accordance with the Financial Conduct Authority (FCA) Rules and Principles and does not place its own interests unfairly above those of its customers. During the course of its investment management activities, from time to time Insight will encounter potential situations where a conflict of interest may occur.
Accordingly, Insight’s policy on managing potential conflicts of interest sets out three overriding principles:
- that Insight does not ordinarily act as principal
- equal treatment of all clients
- effective Chinese Walls between Insight and its parent group
The policy identifies circumstances in which conflicts may arise and how they should be handled.
With regard to voting, the conflicts of interest policy is that Insight will always seek to act in the best interests of its clients when making investment decisions or casting votes on their behalf. Where BNY Mellon, Insight or the clients themselves have business relationships with investee companies, these will be disregarded by Insight in making its investment or voting decisions.