Conflicts of Interest policy

How we identify, manage and review any Conflicts of Interest

​When we're working with multiple parties, there may be situations when a potential Conflict of Interest occurs. We are committed to acting in an ethical manner whenever such a situation arises.

A Conflict of Interest occurs when an individual, or organisation, has conflicting interests with those of their client or between one client and another. This policy outlines how we identify and manage Conflicts of Interest. ​

In this policy the words we, us and our always mean Computershare Investor Services Plc.

​When assessing if a Conflict of Interest has arisen, we will consider:

  • Can there be a financial gain for us, at the detriment of our client(s)?
  • Can the outcome of a service or transaction provided to a client be adversely impacted, to no longer be in the client's interest?
  • Are there financial or other incentives to favour the interests of one client, or group of clients, over the interest of another client?
  • Have there been (or will there be) any inducements, such as money or goods, in relation to the service provided for the client, from a person other than the client?

We maintain a number of internal policies and procedures to prevent and manage Conflicts of Interest. Aspects covered by these policies include the following:​

  • Employees must act in strict compliance with the Anti Market Abuse and Insider Dealing Policy. These procedures ensure that there is appropriate control of sensitive information and employees' interests do not conflict with those of clients.
  • Segregation controls - These are arrangements we have in place from time to time (typically when a company is involved in sensitive corporate events) to restrict access to information held in one part of the business from employees in another.
  • Employees are required to notify us of any outside interest. Any disclosed outside interests will be reviewed by relevant management to consider the potential for Conflicts of Interest, with actions taken where appropriate.
  • Our remuneration policy is designed to balance rewarding employees' experience and performance, with the need to ensure that their remuneration does not conflict with their obligations to clients.
  • Employees are required to comply with a Global Gifts & Entertainment Policy, which includes detailed procedures and controls. For example, under no circumstances can any gift of cash or cash equivalent (such as gift certificates or loans) be accepted.

We will take all appropriate steps to identify (and prevent or manage) Conflicts of Interest, however where we are unable to prevent or manage a Conflict of Interest, we will make a disclosure to impacted client(s) so they can make an informed decision as to whether to enter into or continue with a service.​

​All policies and procedures for the identification, prevention and management of Conflicts of Interest are, as a minimum, subject to annual review and any significant issues will be reported to the Board as necessary.