TT is required to identify conflicts of interest that might arise between TT, the funds it manages, its clients, and between a client and another client, and to manage these conflicts fairly in accordance with FCA Principle 8.
TT’s Conflicts of Interest Policy is appropriate for its size and organisation and the nature, scale and complexity of its business.
Compliance identifies, maintains and regularly reviews a record of the types of activities undertaken by or on behalf of TT in which a conflict of interest arises to assess whether the controls effectively meet regulatory requirements and expectations.
A written report is prepared on a quartlerly basis for the Partners Operating Group (“POG”) on activities which have or will give rise to a conflict of interest which entails a material risk or damage to the interests to one or more of the funds or its investors.
If conflict management procedures are not sufficient to ensure, with reasonable confidence, that risks of damage to client interests will be prevented, TT must clearly disclose the general nature and/or sources of the conflict to the client before undertaking any business for the client, or else refrain from the activity entirely.