Conflict of Interest Policy

Introduction

In the normal course of business, situations resulting in potential or actual conflicts of interest may arise. There is nothing inherently unethical if and when such situations arise, subject to compliance with regulatory and legal requirements. 

However, the abuse of such situations is clearly improper, and Halo Investing MEA Ltd (hereafter referred to as “we”, ‘us” or “our”) is committed to managing these conflicts of interest to prevent abuse and protect our clients, employees, and counterparties.

We are required to take all reasonable steps to identify, manage, record and, where relevant, disclose actual or potential conflicts of interest between ourselves (including our managers and employees and any person directly or indirectly linked) and our clients, and between one client and another, and to have in place a policy relating to conflicts of interest. 

This Policy also considers any conflicts between the interests of other companies within our wider Group of companies (and persons connected thereto) and the duty we owe to a client. We will apply this Policy to all relevant outsourcing and delegation arrangements entered into and in respect of services we may provide to or receive from our wider Group.

Integrity, fairness, impartiality, and primacy of clients’ interests occupy a leading place in our ethical rules and values.

This Policy is designed to address our conflicts of interest management appropriate to the nature, scale, and complexity of our business.

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Purpose of this Policy

The objective of this Policy is to ensure that our employees are able to identify actual and potential conflicts of interest so that these can be recorded, managed appropriately and, where necessary, disclosed to all relevant parties to prevent them adversely affecting the interests of our clients, funds, and their investors and to comply with our regulatory obligations.

This Policy identifies, by reference to the specific services and activities carried out by (or on behalf of) us, circumstances that 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/or ourselves, and outlines procedures to be followed and measures to be adopted to manage such conflicts.

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Conflicts of Interest defined

A Conflict of Interest is a situation where there is a material risk of damage to the interests of a client because the interests of:

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• Us (including all its subsidiaries, representative offices, employees, and the parent entities) and our clients differ; or

• Any client and those of another client differ.

 

An interest is the source of any advantage, direct or indirect, of whatever nature, tangible or intangible, professional, commercial, financial, non-financial or personal.

It should be noted that it is not enough that we may gain a benefit if there is not a potential disadvantage to a client, or that one client to whom we owe a duty of care may gain or avoid a loss without there being an associated possible loss to another client.

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Types of Conflicts of Interest (COI)

When identifying services and activities that may entail a material risk of damage to the interests of a client, we will, as a minimum, considering the following types of conflict:

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• The likelihood that we make a financial gain or avoiding loss at the expense of a client

• Whether we have an interest in the outcome of a service or an activity provided to, or transaction carried out on behalf of, a client that is distinct from the client's interest in that outcome

• Whether we have a financial or other incentive to favour the interests of one client or group of clients over the interests of other clients

• Whether we carry out the same activities performed by our clients; and  

• Whether there are inducements deriving from sources other than the client in relation to the services provided, in the form of monies, goods or services, other than the standard commission or fee for the services in question.

Having identified generic and specific COI risks and circumstances, we will establish and implement effective organizational and administrative arrangements that demonstrate all reasonable steps have been taken to prevent such conflicts from constituting or giving rise to a material risk of damage to the interests of clients.

We will try to avoid COI if possible but, when they cannot be avoided, will seek to ensure that our clients are fairly treated.

Where a potential conflict arises, we will always seek to ensure that transactions and services are not effected on terms that are materially less favourable to the client than those terms that would have been effected had the conflict, real or potential existed.

Where our internal arrangements are not sufficient to ensure, with reasonable confidence that risks of damage to the interests of a client will be prevented, then appropriate disclosure will be made to all relevant parties.

Where we are unable to make such disclosure or consider that the disclosure of the relevant COI would give rise to unacceptable risks, we shall decline to act in the relevant circumstances.

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Responsibilities

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Employee responsibilities

Our employees are responsible for acting in the best interests of our clients and are responsible for reporting actual and potential conflicts of interest to both their line manager and the Compliance Officer.

It is, therefore, the responsibility of all our employees to familiarize themselves with the contents of this Policy and report any COI to the Compliance Officer. All employees have a responsibility for complying with aspects of this Policy that are relevant to them.

All employees must report any COI that they are aware of either personally or in respect of the function they perform within our organization. We all use the COI Capture Form to detail and report all COIs to the Compliance Officer as soon as they are identified.

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Compliance responsibilities

All COI risks identified will be recorded in the Conflicts of Interest Register (‘COI Register’) maintained by our Compliance Officer and when new conflicts are identified, or changes to the risk category or control framework occur, the COI Register will be updated. This ensures that we maintain an up-to-date record of conflicts of interest affecting our business.

The Compliance Officer will produce and oversee the delivery of COI training to all employees, the frequency of which will be determined by Compliance and HR as appropriate.
 

Obligations of our Board

Our Board is ultimately responsible for the proper conduct of our activities. This Policy is set and adopted by our Board and may only be amended by the Board. Our employees will be notified of such changes to this Policy.
 

Clients / Counter-parties

Our open door policy guides our employees, and clients / counter-parties, as well, to report any issues, concerns or activities that they believe in good faith are unethical, questionable or could lead to; a violation of Halo MEA's Conflict of Interest or Halo MEA Code of Conduct.

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When you report a concern, you can expect that your report will be treated seriously, fairly, and promptly. Reporting through our compliance “Voice your Concern” link below, will ensure that your report will be treated as confidential and anonymous should you choose.

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Conflicts Monitoring

All COI are considered and monitored by us on an on-going basis. We maintain a COI Register which inter alia records the types of activities undertaken by us or on our behalf in which a COI entailing a material risk of damage to the interests of our clients may arise or has arisen. This includes consideration of activities carried out by any delegate, sub-delegate, counterparty or external third party (in each case, if appropriate).

Potential COI are considered by our Senior Management regularly, including prior to taking on a new client, changing the scope of an existing mandate, engaging in a new strategy or the material appointment of a new counterparty.

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Last Modified: 31 December 2023

 

MEA6002 / 2.0 / 2312