Our primary responsibility as an investment management firm is to try to add value over the long term. Potential conflicts of interest are addressed by the over-riding principle that client interests are put first.
HSBC Global Asset Management (AMG) businesses have established procedures to identify and manage conflicts between the interests of the AMG business, its affiliates, employees and conflicts between clients.
We have strict procedures to ensure that the integrity of confidential information is maintained and suitable controls are in place to prevent its misuse.
Votes in situations where there may be a conflict of interest are considered in the context of our voting guidelines. Whilst our process allows for departure from vote recommendations based upon our guidelines, special review procedures and an entry in the conflict of interest register are required where we intend to depart from the external recommendation in a conflicted situation.
AMG businesses conduct reviews at least annually on all operations to identify new conflicts of Interest.
AMG businesses present its register of conflicts to the local Risk Management Committee or appropriate governance forum at least quarterly to review the conflicts and agreed mitigation actions.
This policy is described in our Functional Instruction Manual