Within the ambit of its services provision activity and its investment and supplementary services activity, the management Company might find itself in situations of conflict of interest with the Investor. Pursuant to the legislation in force the management Company is required to identify the circumstances that generate or could generate conflicts of interest which could seriously damage the interests of one or more Investors, and to avail itself of an effective conflicts of interest management policy, adequate in reference to the size and organisation of the management Company itself, as well as in reference to the nature, size and complexity of its activities.
The management Company identified a series of situations of conflicts of interest that could arise at the time that the services or the investment activities and supplementary services are provided, and it established the procedures to be followed and the measures to be adopted, in order to manage such conflicts.
Concerning this, the management Company hereby informs the Investor that a situation of conflict of interest, which could harm the interests of the Investor, with regard to the portfolios managed, was identified in the investment transactions aimed at units and shares of the OICRs managed or established by the same management Company, by the parent company Eurizon Capital SGR S.p.A., or by other management companies and SICAVs belonging to the same Group of the management Company, on account of the management Company being at risk of being induced into allocating the Investor's assets in such associated OICRs by reason of the management commissions received through such OICRs.
The mapping of the situations of conflict of interest and the related analysis shall be considered a static representation. The constant product and process innovation, jointly with the significance of factors exogenous to the management Company's sphere of influence, impose a constant conflicts of interest mapping updating activity. To this end, the management Company carries out the mapping updating process, and it takes action, in order to identify all the potential situations of conflict of interest that may arise in the course of providing the investment activities and services offered. The actual situations of conflict of interest so identified are registered in the Register of services and activities that originate prejudicial conflicts of interest, and such Register is kept in compliance with the current legislation.
Concerning the conflicts of interest management policy, also the circumstances about which the management Company is aware of, or should be aware of, which potentially could cause a conflict of interest resulting from the structure and activities of the other companies of the same Group, are taken into account by said policy. The contents of this policy are summarised below. Where specifically requested by the client, the management Company will make the conflicts of interest management Policy available in its complete version.
The conflicts of interest management Policy adopted by the management Company includes a series of organisational, procedural and monitoring safeguards which are formalised in the following documents:
- Autonomy Protocol: it defines the conflicts of interest management Policy adopted by the Company that includes the presence of Independent Administrators, to the end of safeguarding the management companies' decision-making autonomy concerning investment choices. In particular, it defines the trading counterparts selection procedures, and it includes the definition of the general limits applied to the purchases of financial instruments issued or placed by companies of the Group, or by companies that avail themselves of services provided by the companies of the Group, with the involvement of Independent Administrators, made on the account of the managed assets.
- Internal Code of Conduct: it regulates the personal investment transactions of relevant parties, providing specific obligations in terms of preventive communication and authorisation, as well as rules regulating confidential information management.
- Code of Ethics: it regulates the general principles of conduct which the relevant parties shall abide by, and it prohibits receiving gifts that exceed a modest value.
Moreover, a system of controls is formalised for the purpose of verifying the compliance and proper implementation of all the management procedures adopted and the disclosure of any conflicts of interest identified.