We provide here a summary of the policy we maintain in order to manage conflicts of interest in respect of the services we offer.

This policy may be reviewed and amended at any time. This document is not intended to create third party rights or duties or form part of any contractual agreement between the firm and any client.

General Statement of Policy

YLDFX, or any party to whom it may have delegated its functions (a “delegate”), may without priorreference to a client, effect transactions in which the firm or a delegate has, directly or indirectly, amaterial interest or a relationship which may involve a potential conflict with the firm’s duty to theclient. In the event of any such transaction, however, the firm will ensure that:

  1. Such transactions are effected on normal commercial terms negotiated at arm’s length andon terms which are not materially less favourable to the client than if the potential conflict had not existed;
  2. Such transactions do not adversely affect the performance of the firm’s duties andresponsibilities to the client; and
  3. We take reasonable steps to ensure fair treatment for the client.

Identification of Conflicts of Interest

We have sought to identify and assess the materiality of conflicts of interest that may arise in the course of providing financial services.

These include circumstances in which there is:

  • a conflict between the interests of the firm, an individual member of staff, certain persons directly or indirectly connected to the firm or a delegate; and the duty that the firm owes to a client; or
  • a conflict between the differing interests of two or more clients, as the firm owes a separate duty to each of them.

Record Conflicts of Interest

YLDFX maintains a register of those identified conflicts of interest and the controls deployed to mitigate the potential risks arising.

This register is reviewed periodically and the controls are tested to ensure we are effectively managing those conflicts.

Inducements and gifts

YLDFX maintains a general policy on the giving and receiving of gifts and entertainment.

We do not prohibit our staff from receiving small gifts and minor hospitality from other parties. However, no employee or director may accept from, or give to, any person any gift or other benefit that cannot properly be regarded as justifiable in all the circumstances. Employees may not accept gifts from, or provide gifts to, an individual or firm with whom they conduct, or intend to conduct, business on behalf of the firm unless it can be demonstrated that no conflict of interest (actual or perceived) is created by doing so.

Entertainment provided by an employee must fall within any expenses policy the firm may adopt and should not in any event create any conflict of interest. This rule applies even if the direct recipient of the gift or other benefit is the spouse or a child of the employee or some other third party. The provision or acceptance of gifts and entertainment should be consistent and proportionate with the corporate relationship.

YLDFX maintains a register of Gifts and it is the responsibility of employees to notify the firm of any gifts received.

Personal account dealing

Employees may only undertake personal investment activities that do not breach applicable law or regulation, do not unduly distract from their employment responsibilities and do not create anunacceptable risk to the firm’s reputation.

Transactions should also be free from business and ethical conflicts of interest. Employees must never misuse proprietary or client confidential information in their personal dealings and must ensure that clients are never disadvantaged as a result of their dealings.

The firm’s Personal Account Dealing Policy has been established to ensure that personal accountdealing by members of staff comply with this policy.

Investment recommendations

Any investment decisions/recommendations must be fully documented so that any potential conflicts of interest are disclosed at the time and the firm can document how it intends to avoid or manage the conflict with regard to all the facts known at that time.

Managing conflicts of interest

It may not be possible to avoid conflicts of interest from arising. In that case, the firm will endeavour to manage those conflicts of interest by:

DISCLOSURE

We aim to disclose the general nature and/or sources of conflicts before carrying on business for the client. This is to allow the client to consider whether to ask for more information and whether to continue with the service; we do not aim to provide detailed, highly specific or comprehensive information.

Some of the general sources of conflicts that might arise in the provision of our services are explained in the applicable Customer Agreement.

Chinese walls – establishing an information barrier

When the firm establishes and maintains a Chinese wall, it is creating an information barrier. Essentially this requires information held by one part of the business to be withheld from, or not used by, persons in another part of the business. We create and enforce information barriers through our organisational structure, controlling access to information and through physical separation of functions or individuals.

Order Management

YLDFX maintains an Order Execution policy through which we seek to ensure clients are not disadvantaged in their dealings with us. The execution of orders is subject to independent oversight.

1st July 2019