To control conflicts of interest Carthona Capital has:
· identified the conflicts of interest relating to its business;
· assessed and evaluated those conflicts; and
· decided upon, and implemented, an appropriate response to those conflicts.
Conflict management arrangements will be regularly monitored i.e. the Directors (or their delegate), as part of the Compliance Monitoring Program and/or as the business changes, will regularly review Carthona Capital’s conflicts management arrangements to ensure that they continue to be appropriate.
In addition, from time to time at the discretion of the Compliance Committee, an external service provider will undertake a review of compliance procedures and measures. As part of this review, the conflicts management arrangements will also be reviewed to confirm they are adequate to identify, assess, evaluate and successfully control conflicts of interest.
Carthona Capital has a detailed policy for managing conflicts and all conflicts of interests in the investment process are dealt with the investment policy. .