Conflicts of interest disclosure

Conflict of interest policy

As an AIFM, ICP has established and maintains an effective conflict of interest policy. The Conflict of Interest policy has been established to identify, prevent, manages and monitor conflict of interest that might rise between:

• the AIFM and its managed funds;
• the AIF or the investors in that AIF and another AIF or the investors in that other AIF;
• the AIF or the investors in that AIF and another fund managed by the AIFM or the investors in that other fund;
• two clients of the AIFM (if any).

The AIFM will at all times apply effective organizational and administrative arrangements with a view to taking all reasonable steps designed to identify, prevent, manage and monitor conflicts of interest in order to prevent them from adversely affecting the interests of the AIFs and their investors.

Key principles:

• Identification: we proactively identify potential conflicts of interest that may impact the interest of our clients;
• Management: conflicts are managed through appropriate controls, segregation of duties and transparency measures;
• Disclosure: where conflicts cannot be sufficiently mitigated, we disclose them to ensure informed decisions.

Our policy applies to all activities of the AIFM, including control functions (compliance and internal audit, risk management) as well as to any delegation functions and third parties. By implementing robust internal processes, we aim to maintain the highest standards of governance, trust and investor protection.

For further details on the conflict of interests policy, please contact the Conducting Officer – Compliance of ICP at the following email address: b.hartmeier@intervest.com.