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Prevention and management of conflicts of interest

1. Scope of the Policy

The regulations relating to the provision of investment services oblige ANCHOR CAPITAL ADVISORS EAF (hereinafter, the “Entity”) to develop a Conflict of Interest Management Policy, in which it establishes the necessary measures to avoid and manage both conflicts of interest existing as the potential that arise between the Entity and its clients, in the provision of the advisory service on investment matters or auxiliary services. The purpose of this Policy is:

(a) The prior identification of potential conflicts of interest that may arise in the provision of the investment advisory service or auxiliary services by the Entity.

(b) The establishment of measures to manage conflicts of interest, in order to avoid damage to the interest of the Entity's clients.

(c) The establishment and maintenance of the registry of conflicts of interest required by the applicable regulations.

2. Scope of application

For the purposes of this Policy, the circumstances that constitute or may constitute a detriment to the interests of a client or a plurality of clients of the Entity shall be considered conflicts of interest.

Conflicts of interest may arise between:

(a) The interests of the Entity or of the people who provide their services in the Entity, and the Entity's obligations with respect to one or more clients.

(b) The interests of two or more clients of the Entity.

In particular, the Policy applies to:

(i) The members of the Administration Body and Senior Management of the Entity.

(ii) Any other person, both employees or managers of the Entity.

3. Identification of situations potentially generating conflicts of interest

The Entity must identify the types of conflicts of interest that arise when providing the investment advisory service or auxiliary services, the existence of which may undermine the interests of one or more clients.

The scenarios identified by the Entity in which conflicts of interest may potentially arise are the following:

(i) Potential conflicts of interest related to the provision of investment advisory services.

(ii) Potential conflicts of interest that may arise in relation to information flows and members of Senior Management.

(iii) Associations of Subject Persons.

4. General criteria for managing conflicts of interest

In providing services to clients, the Entity must assume as general principles of conduct to act with honesty, impartiality and professionalism, in the best interest of clients, in the terms established in this Policy and in the Internal Code of Conduct of the entity.

Any situation of conflicts of interest arising in the scope of the provision of services by the Entity must be resolved taking into account that:

  • In the event of a conflict between the Entity and a client, the Client's interest must be safeguarded.
  • In case of conflict between clients, favoring one of them should be avoided.
  • If the measures adopted by the Entity to manage conflicts of interest are not sufficient to prevent damage to the interest of one or more clients, the Entity must notify the client of the existence of the conflict of interest.
  • The Entity will adapt its actions to the criteria established in the full version of the Conflict of Interest Management Policy.

5. Incentives

As a general rule, the Entity will not accept or retain fees or commissions or other non-monetary benefits from third parties.

All fees, commissions or monetary benefits received from third parties in connection with the provision of independent investment advice will be transferred in full to the Client and returned to the Client as soon as reasonably possible upon receipt. The incentives transferred will be informed through the periodic informative statements provided to the Client.

The Entity will establish and apply a policy that guarantees that all incentives are assigned and transferred to each client.

Acceptable minor non-monetary benefits will be reasonable and proportionate, and of such a scale that they are unlikely to influence the conduct of the investment firm in any way that is detrimental to the Client's interests.

6. Financial Analysis

In accordance with the applicable regulations in the cases in which the Entity provides non-personalized recommendations on financial instruments, through the preparation of investment reports referring to one or more financial instruments, or those investment reports prepared by third parties for later distribution to the Entity's customers, they must comply with the provisions of this Policy.

The Entity will have:

(i) The obligation to extend the measures defined and adopted for the management of potential conflicts of interest, included in this Policy, to financial analysts and other competent persons whose responsibilities may derive in situations of conflicts of interest with clients to those for investment reports.

(ii) The need to establish measures aimed at guaranteeing compliance with the following conditions by financial analysts and other Subject Persons.