NILGOSC requires its fund managers to have and maintain an effective conflict of interest policy which addresses real or potential conflicts of interest. The processes for identifying, managing and recording conflicts of interest are incorporated into the Investment Management Agreement for each manager. In addition, NILGOSC’s equities fund managers have policies on managing conflicts of interest which are set out in each manager’s Statement of Adherence to the UK Stewardship Code.
In respect of conflicts of interest within NILGOSC, Committee members adhere to a code of conduct which includes express provisions on the disclosure and handling of actual and potential conflicts of interest. In addition, in order to achieve the maximum degree of openness and impartiality, NILGOSC maintains a Register of Members and Officer’s Interests. The Register is available for inspection by appointment at the Committee’s offices and is published on the NILGOSC website in compliance with Freedom of Information legislation. Members and senior officers are required to register their interests on appointment and, thereafter, at the beginning of each financial year. The Committee Code of Conduct can be found on NILGOSC’s website at http://www.nilgosc.org.uk/DataEditorUploads/FOI/Code%20of%20Conduct%20April%202015.pdf