CONFLICTS OF INTERESTS POLICY
Golden Monarque maintains and operates effective organisational and administrative arrangements with a view of identifying, preventing, managing, and monitoring conflicts of interest in order to prevent them from adversely affecting the interests of the Funds managed by Golden Monarque and their investors. These measures are laid down in the Golden Monarque INTERNAL CONFLICT OF INTERESTS POLICY. 1
In order to ensure that all the investments related to the Funds comply with the Funds Management Regulation (LPA) and are done in the exclusive benefit of the funds and its investors, as well as to prevent undue conflicts of interests, Golden Monarque has established an INVESTMENT COMMITTEE, as well as an INVESTMENT COMMITTEE for MPL1 and MPL2, composed, at least, by an independent member with the relevant expertise, and by the members of the Executive Committee.
Therefore, all the investment and divestment decisions, taken by the Board or the Executive Committee of GOLDEN MONARQUE are subject to rigours due diligence proceedings and to a previous unanimous decision of the INVESTMENT COMMITTEE.
Further, in order to prevent any conflict of interest that may adversely affect the interests of the Funds GOLDEN MONARQUE maintains an internal register related to the monitoring of conflict of interests and has implemented the following measures to prevent conflict of interests:
- Members of the Board, managers, employees, as well as Golden Monarque affiliated entities, or entities in which a member of the Board, manager, employee or collaborator, holds more than 20% of the total voting rights and/or in which they have an executive position, may not be engaged by Golden Monarque on behalf of a Fund;
- Golden Monarque permanently follows the activities of the companies in which the funds hold a participation, and when exercising the voting rights held in a fund portfolio, Golden Monarque as representative of the fund, certifies that the exercise of the voting right complies with the LPA of the fund, and exercises the voting rights in exclusive benefit of the fund and its investors;
- GOLDEN MONARQUE, its members of the board, employees, collaborators must not pay or receive any fee or a non- monetary commission (inducements), from services providers or from any other party, in connection with the provision of any service related to the fund.
Further to this, in order to prevent conflicts of interests and undue influence upon employees and managers, the valuation department of Golden Monarque, responsible for the valuation of the funds and its assets, is segregated and functionally independent from the portfolio management department, as well as from the Investment department.
The compliance officer of Golden Monarque is responsible for assuring the compliance with the Internal Golden Monarque INTERNAL CONFLICTS OF INTERESTS POLICY.
1 Upon request, Golden Monarque’ Internal Conflict of Interests Policy will be available to the participants of the funds managed by Golden Monarque.
