The Firm operates a “Policy of Independence” which requires its clients to be treated fairly in instances where the Firm or an employee has a material interest or a conflict in relation to a potential transaction. In such cases, the interest or conflict must be disregarded when advising customers, exercising discretion for them or dealing on their behalf. A material interest can arise, for example, where a firm or an employee has a proprietary position in an investment. A conflict of interest can arise where a firm, an employee or some other connected party has a relationship with another person or entity that potentially conflicts with the duty to the client. Such a relationship might include one with an issuer, another investment manager firm, a broker or counterparty, or another client. In such cases, any investment advice given to a client, or discretion exercised, must be formulated with regard to the client’s interests and not those of the Firm or any connected party or employee.