Conflicts of interest policy.

Our approach. Cavenham Capital Limited maintains a conflicts of interest policy in accordance with the FCA's rules on systems and controls. The policy is designed to identify circumstances that give rise, or may give rise, to a conflict of interest, and to manage those conflicts so as to prevent them from adversely affecting the interests of our clients.

Examples of conflicts we manage. These include conflicts between the firm and a client, between one client and another, and conflicts arising from staff personal account dealing, gifts and inducements, or remuneration arrangements linked to firm or individual performance.

Our controls. We maintain organisational and administrative arrangements to manage conflicts, including separation of the portfolio management and risk oversight functions, a policy on personal account dealing, a gifts and hospitality register, and a record of identified conflicts. Where a conflict cannot be avoided or managed to a degree that protects a client's interests, we will disclose the general nature or source of the conflict to the client before undertaking business on its behalf, or decline to act.

Governance. This policy is reviewed at least annually and is owned by the firm's Compliance Oversight function.

Further information. A copy of our full conflicts of interest policy is available on request from info@cavenhamcapital.com.