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Discretionary Clients Conflict of interest policy

Meltemi Investment Management Limited (the Firm or we) has taken all appropriate steps to identify and to prevent or manage conflicts of interest that it faces in its day-to-day business between the Firm (including its managers, employees, any agents or representatives that might act on our behalf or any person linked directly or indirectly to them by control) and its clients or between one client of the Firm and another client.

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1. The purpose of this policy is to:

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1.1 prevent and identify any potential circumstance which may give rise to conflicts of interest, and which may adversely affect clients’ interests;

1.2 establish appropriate mechanisms and systems to manage those conflicts; and

maintain systems

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2. Governance

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2.1 The Firm’s senior management have overall responsibility for ensuring the Firm’s systems, controls and procedures are adequate to identify, manage and monitor conflicts.

2.2 The Firm’s compliance officer maintains an up-to-date conflicts of interest register to identify and record conflicts of interest that exist, arise or could potentially arise.

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3. Conflicts of interest arise where the Firm or a relevant person, or a person directly or indirectly linked by control to the Firm:

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3.1 is likely to make a financial gain, or avoid a financial loss, at the expense of the client;

3.2 has an interest in the outcome of a service provided to the client or of a transaction that outcome; carried out on behalf of the client, which is distinct from the client's interest in

3.3 has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client;

3.4 carries on the same business as the client; or 

3.5 receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service. 

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4. Conflicts of interest may include but are not restricted to interests between:

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4.1 The Firm and our clients;

4.2 Our staff and our clients;

4.3 Two or more different clients;

4.4 Third parties and our clients; and

4.5 New services/products and our clients.

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5. We have identified the following conflicts may arise:

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5.1 Where we have confidential information regarding an existing or former client which would be of value to another;

5.2 If a transaction carried out on a client’s behalf relates to an investment in respect of which the Firm or an associate may benefit from a commission, fee, mark up or mark down payable otherwise than by the client or the Firm;

5.3 If the Firm acts as agent for a client in relation to transactions in which the Firm is also acting as agent for other clients or associates; and

5.4 Where the Firm is remunerated in a way which encourages it to act against the client’s interests.

 

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6. Where a conflict of interest arises, the interests of the client must always be put before the interests of the Firm. The Firm has the following policies in place to identify and to prevent or manage its conflicts of interest:

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6.1 Staff are required to identify and report conflicts of interest to the Firm’s compliance officer. The compliance officer will decide what the appropriate action to take is;

6.2 All research is paid for out of the Firm’s own resources, as opposed to from client’s resources;

6.3 The Firm does not enter into arrangements that could compromise its ability to comply with its order execution policy, which sets out the Firm’s policy regarding order aggregation and best execution;

6.4 The Firm has a policy designed to minimise the risk of conflicts arising in situations where staff receive or provide gifts/inducements from or to clients or third parties;

6.5 The Firm carries out due diligence and on-going monitoring of any vendors and third parties it appoints;

6.6 The Firm has a personal account dealing procedure to reduce potential conflicts in situations where staff deal on own account;

6.7 The Firm has an independence policy that requires staff to disregard any material interest or conflict of interest when advising a client or dealing for a client; and

6.8 The Firm’s remuneration arrangements ensure that remuneration is not solely or predominantly based on quantitative commercial criteria. The Firm’s remuneration arrangements adhere to compliance requirements and take the fair treatment of clients into account.

 

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7. Conflicts of interest disclosure

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7.1 In exceptional circumstances, a conflict of interest may arise that the Firm is not able to prevent or manage so as to avoid the risk of damaging client interests. In such a circumstance, the activity concerned must not be undertaken or the Firm will clearly disclose to the client the general nature of the conflicts and the steps taken to mitigate those risks before undertaking business for the client.

7.2 Any such disclosure will be in a durable medium (e.g. in writing) and will clearly state that the organisational and administrative arrangements established by the Firm to prevent or manage that conflict are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of the client will be prevented.

7.3 The disclosure will include a specific description of the conflicts of interest that arise in the provision of investment and/or ancillary services, taking into account the nature of the client to whom the disclosure is being made.

7.4 The description will explain the general nature and sources of conflicts of interest, as well as the risks to the client that arise as a result of the conflicts of interest and the steps undertaken to mitigate these risks, in sufficient detail, taking into account the nature of the client, to enable the client to take an informed decision regarding the service with respect to which the conflict of interest arises.

 

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8. Annual review of our policy

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8.1 We monitor the effectiveness of the procedures for conflicts of interest on an ongoing basis and will review the policy at least once a year.

Meltemi Investment Management Limited
28 Ives Street, London, SW3 2ND
+44 (0)20 3795 8147 +44 (0)20 3795 8146 investments@meltemi.biz

Authorised and regulated by:
Financial Conduct Authority
12 Endeavour Square, London, E20 1JN

This site is issued and operated by:
Meltemi Investment Management Limited
Registered in England: No. 4696452
Registered Office: 28 Ives Street, London SW3 2ND

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