Information about dealing with conflicts of interest

We prioritize ethics, transparency, and governance. The Company shall conduct its services and its own business in such a manner that existing and potential conflicts of interest are managed in a proper manner. In dealing with conflicts of interest, the Company shall comply with the relevant legal requirements and the regulations issued by the relevant supervisory authorities on the handling of conflicts of interest.

Conflicts of interest can arise between:

• the Company and an investor or an AIF managed by the Company;

• the group of companies to which the Company belongs and an investor or an AIF managed by the Company;

• an affiliate of the Company and an investor or an AIF managed by the Company;

• employees, the bodies or members of the Company (including persons who directly or indirectly control the Company) and an investor or an AIF managed by the Company;

• a contractually bound intermediary (as well as its employees, bodies, etc.) of the Company and an investor or an AIF managed by the Company;

• natural persons involved in the provision of services by the Company (e.g. under an outsourcing agreement) and an investor or an AIF managed by the Company;

• two or more investors in connection with the provision of services by the Company to AIFs in which those investors are invested; or

• two or more AIFs managed by the Company in connection with the provision of services by the Company to such AIFs.

Embla shall take the following measures to avoid conflicts of interest, depending on the circumstances of the individual case:

Follow organisational procedures and processes

• Separation of functions

• Information exclusions and blocks

• Special monitoring of individuals

• Removal of financial incentives

• Temporary suspension of authority to issue directives

• Exclusion of certain activities
  

Embla  review, monitor, refine and improve this policy regularly in order to most appropriately deal with conflicts of interest.