The policy on managing potential conflicts of interest in the investment process is part of our Code of Conduct. Quoniam has adopted the BVI Rules of Conduct (BVI Wohlverhaltensregeln), which are published by the German Association of Investment Management (BVI) and is also committed to the Efama Code of External Governance. Acceptance of these guidelines is mandatory for all employees and includes rules on personal securities trading, acceptance of gifts and entertainment, money laundering, compliance with laws, regulations and company policies, and prohibits payments and contributions.
Additionally, Quoniam has a proprietary policy on conflicts of interest disclosed to public. In this proprietary policy potential conflicts of interest are defined, principles are phrased and measures are taken in order to avoid conflicts of interest.