Conﬂicts of interest, including those relating to matters of Responsible Investment, are managed according to the LGPS Central's Conﬂicts Policy, which is made available to all clients and is included in the Firm’s Policy Manual. Our Conﬂicts Policy is made available to all clients as part of the take on process and when it has been materially changed. The policy addresses the requirements of the Markets in Financial Instruments Directive (MiFID) which include the following action for the purposes of managing conﬂicts of interest:
a) ﬁrms must take all reasonable steps to identify and manage conﬂicts of interest between themselves and their clients, or between one client and another that arise in relation to the provision of investment and ancillary services
b) ﬁrms must maintain and operate eﬀective organisational and administrative arrangements with a view to taking all reasonable steps designed to prevent conﬂicts of interest from adversely aﬀecting the interests of the client
c) where such measures are not suﬃcient to ensure, with reasonable conﬁdence, that risks of damage to client interests will be prevented, the ﬁrm must clearly disclose the general nature/or sources of conﬂicts to the client before undertaking business on its behalf.