At CS Investment Managers, we are committed to the fair treatment of our clients and to putting the interests of our clients first. However, it is recognised that in the course of providing investment management services, we act for a wide range of clients, and that situations may arise which could create conflicts.

In accordance with regulatory requirements, therefore, policies and procedures have been established as part of CS Investment Managers’ compliance management programme, which is aimed at managing or preventing conflicts. This is an integral part of our organisational and administrative arrangements and enforced through regular monitoring and training.

This compliance framework consists of an overarching Conflicts of Interest Policy, and the procedures put in place to implement it. This Conflicts of Interest Policy explains how CS Investment Managers will:

• identify circumstances which, in the course of providing our services, give or may give rise to conflicts of interest entailing a material risk of damage to clients’ interests;
• maintain systems designed to prevent the circumstances identified above from constituting or giving rise to a material risk of damage to clients’ interests; and
• where appropriate (i.e. where the conflict cannot be effectively managed) disclose any conflict or potential conflict to all interested parties. This would only be considered if, after due consideration by Compliance, there was no other way to effectively manage the conflict.

The aim is to ensure that controls are in place to achieve these objectives, and that clients and employees alike have sufficient information with which to understand the actual or potential conflicts that may arise, and the steps taken to mitigate them. Management will review frequently the Conflicts Registers and ensure that any conflicts are identified and appropriately managed.

Please note: CS Managers Ltd, its Directors, employees and associates may have a position or engage in transactions in the same securities as our clients. The overriding principle is that employees must always place clients’ interests before their own and those of the Company and the Company’s directors and employees. They must disregard any other relationship, arrangement, material interest or conflict of interest which may materially influence, or appear to materially influence, any service provided to a client, including the giving of advice or recommendations.