Coeli's management team must work actively to continuously identify, monitor and manage any conflicts of interest that may arise in the business.
Employees shall immediately inform their immediate superior or the Compliance function of situations where any conflicts of interest have been identified or may arise.
Identified existing and potential conflicts of interest should be documented in a special log that is administered by the Compliance function. The documentation must contain information on how the conflict of interest is handled.
In particular, Coeli shall assess the existence of any conflicts of interest associated with the following situations:
▪ When developing new or substantially changing products and services
▪ When entering into new contract agreements
▪ When entering into agreements with new counterparties for portfolio transactions in the funds
▪ In case of other material changes to the business, such as acquisitions or mergers of companies, recruitment of board members, etc.
The above situations should always be considered in connection with the annual audit of the guidelines.