Conflict of interest disclosure

General

Fort Nami Limited is regulated by the Financial Services Commission, Mauritius and holds an Investment Dealer (Full Service Dealer, excluding Underwriting) Licence.

In the course of providing investment services, circumstances may arise in which the interests of Fort Nami Limited, its directors, officers, employees, representatives, related parties or other clients differ from, or may conflict with, the interests of a client.

Fort Nami Limited is committed to identifying and managing actual or potential conflicts of interest fairly and in accordance with applicable legal and regulatory requirements.

Identification of conflicts

Fort Nami Limited maintains arrangements designed to identify circumstances that may give rise to a conflict of interest involving a material risk of damage to the interests of one or more clients.

Potential conflicts may arise, for example:

• between Fort Nami Limited and a client;
• between different clients of Fort Nami Limited;
• between a client and a director, officer, employee or representative of Fort Nami Limited;
• in connection with personal transactions or interests of relevant persons;
• in connection with relationships with brokers, counterparties, service providers or other third parties; or
• where Fort Nami Limited or a related party has a financial or other interest in a transaction involving a client.

Management of conflicts

Fort Nami Limited maintains policies, procedures and organisational arrangements designed to prevent or appropriately manage identified conflicts of interest.

Depending on the circumstances, these measures may include appropriate segregation of duties and responsibilities, controls over access to information, oversight arrangements, restrictions relating to personal transactions and other measures considered appropriate having regard to the nature of the conflict.

Disclosure of conflicts

Where the arrangements maintained by Fort Nami Limited are not sufficient to ensure, with reasonable confidence, that the risk of damage to a client's interests will be prevented, the nature and/or source of the relevant conflict may be disclosed to the client in accordance with applicable legal and regulatory requirements.

Such disclosure will be made in sufficient detail to enable the client to make an informed decision concerning the service or transaction in the context of which the conflict arises.

Where a conflict cannot be appropriately managed, Fort Nami Limited may decline to act or may refrain from entering into the relevant transaction.

Client interests

Fort Nami Limited seeks to conduct its business honestly, fairly and professionally and to manage conflicts of interest in a manner consistent with applicable Mauritius laws, regulatory requirements and the interests of its clients.

Further information regarding Fort Nami Limited's conflicts of interest arrangements may be provided to clients where appropriate.