Conflicts Statement

Tellimer is an independent information services provider

Tellimer is an independent information services provider, and does not provide banking, broking, custody, asset management or portfolio advisory services to its clients; all analysis produced by the in-house team must express a view genuinely held as a result of analysis.

Although the risk of conflicts is mitigated by its business model, Tellimer nevertheless has policies and procedures in place to mitigate the risk of conflicts of interest between its clients, contacts and other stakeholders.

Purpose of the Conflicts of Interest Policy

Tellimer is committed to maintaining integrity and professional standards in providing services to its clients. It seeks to identify circumstances that may give rise to conflicts of interest or lead to risk or damage to a clients' interest and to establish appropriate mechanisms and systems to manage those conflicts.

Conflicts of Interest

Tellimer seeks to identify conflicts of interest that exist in its business which are associated with its service provision. Tellimer has put in place measures it considers appropriate to the relevant conflict(s) to monitor, manage and control the potential impact of those conflicts on its clients. The conflicts identified based on the investment activities provided by Tellimer are outlined below:

• those between clients with competing interests;
• those between clients and Tellimer where their respective interests in an outcome may be different; or
• those between the personal interests of an employee of Tellimer and the interests of Tellimer or its clients where those interests may be different;

Policies and Procedures

Tellimer has procedures in place to address conflicts of interest. The following lists the key measures Tellimer takes to safeguard the interests of its clients:

1. Integrity and Standards of Conduct

   Tellimer expects that its employee act with integrity at all times. The induction programme, training, competency, and procedures aim to ensure the professional integrity of the Tellimer team.

2. Outside Business Interests

   Employees must inform, and seek approval from, the compliance department about material outside business interests.

3. In-house Research

   Production and dissemination of research by the Tellimer in-house analyst team may give rise to several conflicts of interest, as outlined below:

   • Remuneration: Other departments do not take decisions on coverage, timing or content of research. The Firm’s remuneration policy is designed to avoid rewarding behaviour that may lead to the disadvantage of its clients Research analysts’ remuneration is not linked to research recommendations.
   • Distribution of Research: The Firm has a policy that requires simultaneous distribution of research to all relevant clients simultaneously.
   • Information Management: The research department is subject to a “clear desk policy” and is positioned in such a way that employees outside the research information barrier cannot see documentation regarding the timing or detailed content of planned research.

4. Inducements to Employees from Clients

   Employees are not allowed to accept gifts, entertainment or any other inducement from any person which might benefit one client at the expense of another when conducting business and must always comply with the Gifts and Entertainment Policy. If any client attempts to put pressure on an employee to influence their opinion they must report it to their manager as a matter of urgency.

   Any gift or hospitality given, or received, by the firm or employee will not be in compliance with conflicts of interest requirements, if it is not designed to enhance the quality of the relevant service to the client, or it impairs the firm’s ability to act honestly, fairly and professionally in accordance with the best interest of its clients.

   The giving or receiving of a gift and/or entertainment can only be justified when it:

   • enhances the quality of the service where it can be shown that additional or a higher level of service is provided; and
   • directly or indirectly provides a tangible benefit to the client or clients more generally.

5. Remuneration Policy

   All relevant employees who are open to a conflict of interest are paid a basic salary including those in key support areas such as Finance, Legal and Operations. This salary is not dependent on Tellimer’s performance. A bonus structure may be put in place which is linked to Tellimer’s performance, team performance and/or the individual’s performance. Payment of any bonus is at the discretion of senior management.

6. Separate Supervision and Segregation of Functions

   Where appropriate, Tellimer has arranged for the separate supervision of those carrying out functions for clients whose interests may conflict, or where the interests of clients and Tellimer may conflict. Tellimer has taken steps to prevent the simultaneous or sequential involvement of a relevant person in separate services or activities where such involvement may impair the proper management of conflicts of interest.

7. Independence

   Tellimer employees are required to act independently when carrying out their day-to-day duties and obligations during their employment.