Managing conflicts of interest

In accordance with the legal requirements, BENDURA Funds Inc. informs you below about its measures in dealing with and disclosing conflicts of interest in the area of fund management.

Conflicts of interest cannot always be completely avoided within a fund management company that provides a variety of services for its clients. The company therefore endeavours to ensure fair treatment of all business partners.

Conflicts of interest can arise between our company on the one hand and business partners, employees, and companies within our group of undertakings on the other hand. Conflicts of interest can also arise between different business partners, between business partners and employees, and between employees and the companies within our group of undertakings.

Conflicts of interest could arise in the following forms:

• the receipt and granting of benefits (e.g. gifts, invitations to meals, travel, or hotel accommodation) from or to third parties,
• the execution of external mandates (e.g. participation in political associations, boards of directors or other bodies) by members of the management or employees,
• the interest in generating revenue for the undertaking or group of undertakings,
• the performance of double functions by employees within the group of companies,
• transactions between funds managed by us (cross trades),
• predominant performance-related compensation for employees,
• the position as a company within a group of undertakings vis-à-vis third-party customers,
• personal relationships between our Executive Board members or employees and business partners,
• obtaining information that is not publicly known (insider information), or
• the simultaneous interests of several clients in the acquisition or sale of a specific target investment.

In order to prevent potential conflicts of interest from arising, attention was paid to separate functions, in particular activities that are incompatible with each other. The separation of functions applies throughout  the company and up to the level of top management. In addition, there is an independent and permanent compliance function in place that monitors business activities of the company. Moreover, all employees are committed to high ethical standards, which are intended, among other things, to ensure early identification, avoidance and management of conflicts of interest. We expect accurateness, honesty and professionalism at all times in line with market standards, regulatory and legal requirements and business partner interests.

Among other things, we have established the following additional measures to avoid or identify potential conflicts of interest at an early stage:

• obligation to comply with the Code of Conduct,
• maintaining an ongoing register of conflicts of interest,
• guidelines on the acceptance and granting of benefits and disclosure requirements,
• no predominant performance-related remuneration (see information on remuneration policy),
• four-eyes principle,
• regular training and further education of employees,
• ongoing reporting of identified conflicts and their management,
• process for the structured launch of new products and services,
• obligation for employees to disclose transactions in financial instruments that may be of interest to us to the compliance function,
• maintenance of restricted lists (if any),
• maintenance of an insider or monitoring list (if any) to monitor the emergence of sensitive information and prevent its misuse,
• selection procedures for delegation takers to protect the interests of business partners,
• monitoring of the portfolio turnover rate,
• procedure for the acquisition and allocation of target investments.

General information:

Our company may receive free of charge contributions from other service providers as part of our service provision. These may be in the form of financial analyses, other information material, trainings, or access to third-party information systems. The receipt of such benefits is not directly related to the services provided. The company only uses these benefits to provide and further develop high quality services for its business partners.

We are at your disposal for information, queries, and complaints:

Telephone: +423 399 400-0
E-Mail: contact@bendurafunds.li