Avellemy is part of the Ascot Lloyd Group. Avellemy shares a common conflicts of interest policy, oversight processes and control framework.
Avellemy takes all appropriate steps to prevent conflicts of interest. Where a conflict of interest cannot be prevented, Avellemy takes all appropriate steps to manage and monitor those conflicts of interests. Potential conflict may arise between:
- Avellemy (extending to all relevant persons which include employees and group employees, their family, friends and business associates), and a client; or
- Different entities within the wider Ascot Lloyd Group; or
- One client of the Ascot Lloyd Group and another client.
Circumstances will be treated as giving rise to a conflict of interest where Avellemy may gain a benefit and there is an associated possible disadvantage to a client, or where one client may gain a benefit or avoid a loss and there is an associated potential loss to another client.
Avellemy has developed and implemented a robust conflicts of interest framework, which includes the identification, management and monitoring of such conflicts. A conflicts of interest register is maintained detailing potential conflicts impacting Avellemy and the internal controls and procedures in place to manage and mitigate the risks associated with those potential conflicts. The conflicts of interest register and policy are reviewed periodically and as and when there is significant business change, so they are kept up to date and relevant to the business.
As part of its governance framework and other internal procedures, Avellemy has established several key organisational and administrative arrangements and internal control systems within its business which are designed to prevent, manage and monitor these potential conflicts in order to prevent harm to its clients.
These systems and controls include Avellemy’s segregation of any tasks and responsibilities which may give risk to potential conflicts of interest and Avellemy’s assessment of whether material conflicts of interest may arise as a result of its operating conditions. They also aim to ensure sufficient independent where relevant persons may be engaged in business or activities which could give rise to such potential conflicts.
Avellemy’s systems and controls are also reviewed and monitored by its Risk and Governance Committee, which includes the conflicts of interest framework. The Risk and Governance Committee will monitor conflicts of interests and the adequacy and effectiveness of the controls that have been implemented to manage such conflicts periodically.