ENVERCAPITAL
CONFLICTS OF INTEREST POLICY
INTRODUCTION
When acting for our clients, Envercapital (“Enver”) must always act with the utmost integrity to act in our client's best interests, and put the interests of our clients ahead of those of our own and the Envercapital Group.
We are required to:
- Take all appropriate steps to identify conflicts of interest between:
- Us and one of more of our clients;
- An employee and one or more of our clients;
- Two or more of our clients; and
- A third-party service provider and one of our clients.
- Maintain and operate effective organisational arrangements with a view to
taking all appropriate steps to prevent conflicts of interest from constituting
or giving rise to a material risk of damage to the interests of our clients.
- Establish, implement and maintain an effective written conflicts of interest
policy (the “Conflicts of Interest Policy”) which identifies those conflicts of
interest which constitute or may give rise to a conflict of interest entailing a
material risk of damage to the interests of one or more clients and the
procedures which are followed to manage and mitigate such conflicts that
cannot be prevented.
- Make full and fair disclosure to clients of all material facts about their
business relationship with us, particularly regarding conflicts of interest
A conflict may arise where Enver and / or its employees
- Are likely to make a financial gain or avoid a financial loss at the expense of the
client;
- Have an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client's interest in that outcome;
- Have a financial or other incentive to favour the interest of another client or group of clients over the interest of the client;
- Carries on or has a significant interest in the same activities as the client;
- Receives, or will receive, from a person other than the client, an inducement (other than an acceptable minor non-monetary benefit) in relation to the service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service;
This document summarises the Enver Conflicts of Interest Policy and provides key information on how actual and potential conflicts of interest are identified, prevented or managed, documented and monitored within Enver.
IDENTIFYING, PREVENTING, RECORDING AND MANAGING CONFLICTS
All employees of Enver are required to identify any actual or potential conflicts of interest and report it to their line managers and to the compliance team as soon as possible.
Enver maintains and regularly updates records of actual and potential conflicts of interest identified in its conflicts register. These conflicts are managed via our organisational arrangements, systems and controls, and governance framework, to prevent damage to the interests of clients. These include, but are not limited to:
- The Enver governance structure, including the Enver Risk Committee which is responsible for the oversight of conflicts management.
- Putting in place written policies and procedures to manage conflicts including, a code of ethics and a compliance manual. These policies and procedures are subject to Enver's regular independent review and monitoring processes;
- Providing training to our staff on conflicts management;
- Appropriate segregation of duties and the implementation of information barriers, including ethical walls within Enver, and between Enver and other members of the Enver group;
- Separate supervision and reporting lines in relation to those business lines whose interests may conflict as well as reporting and challenge at control groups and other governance forums.
- Regular monitoring by our compliance team and assessment by our risk team.
We consider these measures appropriate to prevent or manage the conflicts arising to avoid the material risk of damage to client interests.
DISCLOSURE
If Enver's organisational arrangements and all reasonable efforts taken to prevent or manage conflicts of interest are not sufficient to ensure, with reasonable confidence, that the material risks of damage to the interests of a client will be prevented, Enver will clearly disclose the specific description of the nature and sources of the conflict to the client.
Such disclosure will be made prior to the conclusion of a contract, and in a durable medium to the client and include sufficient detail of the conflict and the steps undertaken to mitigate these risks, to enable the client to take an informed decision with respect to the service in the context of which the conflicts of interest arise.
As at the date of this statement, Enver does not have any conflicts where the measures in place do not sufficiently mitigate the conflict and the risk of harm to the client.
In an extreme case where we consider that the conflict of interest is too great and cannot be managed in any other way (including by disclosure), we may decline to act for the client.
SUMMARY OF CONFLICTS OF INTEREST
A summary of the principal conflicts that exist within Enver, and the steps taken to prevent or mitigate them are set out below.
Personal Transactions
All employees and connected parties are required to adhere to Enver's code of ethics. This is in place to ensure that any such dealing does not involve conflicts of interest or misuse of insider, proprietary or client confidential information, and that clients are not disadvantaged because of these dealings. All employees of Enver must report and pre-clear their personal transactions.
Gifts and Entertainment
Enver has a policy and procedures in place, including strict limits on the frequency and value, to ensure that gifts and entertainment given or received are justifiable in the circumstances and unlikely to influence the professional judgement of the persons concerned. A central record of gifts and entertainment is maintained by the compliance team.
Inducements
Enver is dedicated to providing honest, fair and professional services to its clients. For this reason Enver operates on the basic premise that no inducements (monetary and non-monetary benefits) are received in relation to the investment service and /or ancillary service, unless these qualify as an acceptable minor non-monetary benefit (i.e. they are capable of enhancing the quality of service provided to a client and are of a scale and nature that they could not be judged to impair compliance with Enver's duty to act in the best interests of the client.)
Enver may from time to time receive research from independent research providers to assist in the provision of its services to clients. Enver pays for the research its consumes out of its own funds.
Outside Business Interests
No Enver employee may engage in any additional outside business activities that may conflict with the interests of Enver and its clients, including directorships or personal fiduciary appointments, without prior written approval from the compliance team and the relevant executive board member. Compliance maintain a register of all outside business interests and evaluate on an annual basis whether any conflicts arise.
Remuneration
Enver has a remuneration policy in place that ensures that its employees are not only remunerated based on quantitative commercial criteria, but also on criteria that consider compliance with regulations, the fair treatment of clients and the quality of services provided to clients.
MONITORING
A periodic exercise is undertaken to identify actual or potential conflicts of interest within Enver, and these are recorded in the Enver conflicts of interest register which is maintained by the compliance team, and reviewed annually, or upon any material change.
The Enver risk committee is ultimately responsible for overseeing the identification and management of conflicts, and maintenance of the conflicts policy at Enver, which it periodically reviews.
The compliance team undertake periodic monitoring of disclosed conflicts as part of the annual compliance monitoring programme.
FURTHER INFORMATION
If you would like further information on the above, please contact your usual contact at Enver or the compliance team.
Updated - 23 February 2022
