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.