Per Morphic Responsible Investment Policy, section 5.2 Managing Conflicts of Interest:
Morphic Asset Management (Morphic) maintains a Compliance Manual (signed off by the Independent Board of Directors) which all employees receive on commencement of employment and review annually.
The Compliance Manual provides the framework and rules by which Morphic defines itself and its relationships with its stakeholders including clients, staff and shareholders. Section 3 of Morphic's Compliance Manual “Managing Conflicts of Interest” addresses this specific issue as follows:
- Definition of conflicts of interest
- Procedures for managing conflicts of interest
- Mechanisms for controlling conflicts of interest
- Monitoring and reporting