Conflicts of Interest Policy

Conflicts of Interest Policy – TURNOVER

  1. KEY DATA

Summary

This Policy sets out the arrangements in connection with the identification, documentation, escalation and management of conflicts of interest for the TURNOVER

 

Conflicts of Interest Policy – TURNOVER

  1. INTRODUCTION

As a global asset manager and financial services provider, conflicts of interest are inherent in  (TURNOVER) business. It is essential that TURNOVER (Turnover investment management llc ) is able to identify actual or potential conflicts of interest and manage them fairly and appropriately, including preventing a conflict of interest from adversely affecting the interests of a Client. Conflicts of interest can arise in many contexts, some of which may arise from belonging to the Another company . For example, in addition to conflicts of interest that may arise between TURNOVER and a Client, potential conflicts of interest can arise between one Client and another, an Employee (or Third Party Representative) and a Client, or between TURNOVER and its various share- holders.

Management are responsible for putting a framework in place and implementing systems, controls and procedures to identify, escalate and manage conflicts of interest. Every Employee, however, is responsible for identifying and escalating potential conflicts of interest so that they may be appropriately managed and resolved.

The failure to identify, escalate and appropriately manage actual or potential conflicts of interest and to comply with relevant Rules may expose TURNOVER and Employees to fines, penalties, judgments, damages, and settlements related to regulatory or legal actions and may result in damage to TURNOVER’s reputation and a general loss of trust.

 

  1. DEFINITIONS/GLOSSARY

Unless otherwise defined, capitalized terms used in this policy have the following meanings:

  Term

   Definition

 ”TURNOVER ”

means Turnover investment management llc,its domestic and foreign branches, its representative offices and Turnover Group Entities;

   “Client”

  means any of the following:

  1. a) an existing client of TURNOVER
  2. b) a potential client of TURNOVER (where TURNOVER is seeking to enter into a relationship with the potential client in respect of services or trans- actions); or
  3. c) a former client of TURNOVER where fiduciary or other duties remain in place;

   “Close Personal Relation- ship”

   means any of the following:

  1. a) a romantic relationship of an Employee;
  2. b) a personal business, commercial or financial relationship;
  3. c) a cohabitee of an Employee;

 “COI Framework” “Turnover Group Entity”

TURNOVER Entity

means the conflicts of interest framework for the oversight and governance of conflicts of interest;

means any legal entity in which Turnover llc directly or indirectly, holds more than 50 per cent of the equity or voting capital share (or equivalent);

means any legal entity in which Turnover Group, directly or indirectly, holds more than 50 per cent of the equity or voting capital share (or equivalent);

     Turnover Group (TURNOVER )

   stand-alone asset management business of the Turnover llc, consist of Turnover Group Financial Holding and listed Company), Turnover Management TIML (General Partner Company) and any Turnover Group entity

    “Employee”

   means any of the following:

a) a permanent or temporary employee of TURNOVER;

b) a Board Member whether or not an employee of TURNOVER; or

c) a natural person employed by TURNOVER as a contractor;