The following is an extract of the Fund's IGF in relation to conflict management:
The Trustee has a Conflicts Management Framework which outlines the Board’s approach to ensuring that the Fund takes reasonable practicable action to identify, avoid and/or prudently manage all actual and potential conflicts of interest.
In addition to the measures set out in the Conflicts Management Framework the following controls are in place to manage the risk that investment decisions are made other than in the best interests of members.
Investment Team Conflicts Management
A conflict of interest notification and reporting process is in place for all members of the internal investments team to ensure transparency in decision making. The process is the responsibility of the Manager, Investment Governance and Legal however, all members of the internal investments team have accountability for the notification and management of their own conflicts.
An interest register is maintained ensuring all actual or perceived conflicts are recorded and appropriately controlled for each member of the internal investments team. Pecuniary interests such as superannuation accounts and other investments of both members of the internal investments team and their family members are disclosed and no materiality threshold is applied to ensure transparency in decision making. The internal investments team are prompted to raise any new conflicts or changes to existing conflicts regularly at internal investments team meetings.
The Chief Strategy and Risk Officer and the Senior Manager, Governance have oversight of this register and reporting process.