Introduction
Conflicts of interest may arise in the course of providing our services. If not properly managed, they may create a risk of harm to our Customers or to P1 (“P1”, “we”, “us”).
P1 maintains systems and controls designed to identify, record, monitor, and manage conflicts of interest. This policy sets out how P1 handles such conflicts to ensure fairness, transparency, and integrity.
This document does not create third-party rights or form part of any contractual agreement.
2. What is a Conflict of Interest?
A conflict of interest exists when P1 or any of its Employees has a personal, financial, or professional interest that may compete with:
the interests of a Customer, or
the interests of P1 itself.
Conflicts may be:
Actual - a real conflict exists
Apparent - a reasonable person may perceive a conflict
Potential - a situation could develop into a conflict
Examples include:
P1 gaining a benefit while a Customer may suffer a disadvantage
One Customer benefiting at the expense of another
Staff having external interests that influence their decisions
Conflicts must be managed even if no improper action occurs.
Treating Customers Fairly is central to P1’s values. We maintain a culture that recognises and mitigates conflicts proactively.
3. Identifying Conflicts of Interest
P1 takes all appropriate steps to identify conflicts between:
P1 (including employees, directors, and persons linked to P1), and
Customers of P1, or
Customers and other Customers.
We also consider conflicts arising from:
third-party inducements
remuneration structures
external relationships
personal interests of staff
3.1 Factors We Consider
We assess whether P1 or its Employees might:
gain financially at a Customer’s expense
have an interest in a Customer’s transaction that differs from the Customer’s interest
have an incentive to favour one Customer over another
carry on the same business as a Customer
receive benefits from third parties related to Customer services
3.2 Other Situations
Conflicts may also arise when:
approving new products or services
launching new business lines
entering partnerships or collaborations
changing operational processes
3.3 New Conflicts
The delegated Risk Officer reviews all newly identified conflicts and determines whether:
existing controls are sufficient
additional controls are required
disclosure to Customers is necessary
4. Recording Conflicts
P1 maintains a record of all identified conflicts of interest, including:
actual conflicts
potential conflicts
conflicts that may arise during ongoing services
This ensures transparency and accountability.
5. Managing Conflicts
P1 implements arrangements to prevent conflicts from harming Customers. These include:
mandatory staff training
disclosure of competing interests
a Gifts, Hospitality & Third-Party Benefits Policy
restrictions on outside business interests
independent reporting lines
segregation of duties where appropriate
6. Disclosure of Conflicts
If P1 cannot fully prevent a conflict from affecting a Customer, we will disclose:
the nature of the conflict
the source of the conflict
the risks to the Customer
the steps taken to mitigate the conflict
Disclosures:
are made in a durable medium (email or letter)
are issued before providing the relevant service
must be approved by the Head of Compliance
include sufficient detail for the Customer to make an informed decision
Disclosure is a last resort - P1 always seeks to manage conflicts internally first.
7. Outside Business Interests
Employees must disclose and obtain written approval before engaging in any outside business activity, including:
employment with another entity
acting as a contractor or consultant
serving as a director, officer, or partner
receiving referral fees or commissions
any compensated activity outside P1
Charitable activities generally do not require approval unless compensated or investment-related.