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Talaria Asset Management

PRI reporting framework 2019

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage (Private)

SG 01 CC. Climate risk (Not Applicable)

SG 02. Publicly available RI policy or guidance documents

New selection options have been added to this indicator. Please review your prefilled responses carefully.

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.



02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.


02.3. Additional information [Optional].

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Our Conflict of Interest policy is based on:


The potential for conflicts of interest is minimised as our business is structured in a way that the goals of Wingate and its clients are in alignment.

All clients are treated equally and purchases and sales are carried out on a pro-rata basis. If pro-rata distributions are not possible, it is our policy that related accounts receive less favourable treatment than nonrelated accounts.


All employees must be alert to conflicts of interest, which may arise from:

- Remuneration, fees, or any other pecuniary or non-pecuniary benefits (including, but not limited to soft dollar benefits) 

- The use of non-public information.

- Personal interests which are inconsistent with those of Wingate and/or its clients interests. 

- Competing interests of different client groups, or individual clients.


The policy stipulates that we make adequate disclosure in enough detail to allow clients to make an informed decision about how the conflict may affect the service being provided to them, before making an investment decision.

Monitoring and Audit

We have in place monitoring and auditing arrangements to ensure that any non-compliance with these conflict management arrangements are identified and appropriately acted upon.

03.3. Additional information. [Optional]

We have in place a more detailed policy on managing potential conflicts of interest and are happy to share this document with clients.

SG 04. Identifying incidents occurring within portfolios (Private)