Galliard’s compliance team conducts a risk assessment and maintains an inventory of potential conflicts of interest, both of which are updated annually. Members of the Compliance Committee participate in the annual review of conflicts and risks to discuss anything potentially new or changing as well as anything no longer applicable. Conflicts of interest and risks are mapped to applicable compliance policies or other controls that are designed to mitigate potential issues as well as to confirm that potential conflicts and risks are appropriately disclosed in the applicable disclosure materials.
In addition, Galliard employees are subject to Galliard’s Code of Ethics and other conduct policies which have certain requirements which are designed to prevent conflicts of interest. Examples include, but not limited to, pre-clearance and/or quarterly and annual reporting of applicable personal trading, outside business activities, gifts and business entertainment give and/or received and political contributions.