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Conflicts of Interest

We have set a policy on the management of conflicts of interest with the objective of taking all reasonable steps to identify and manage conflicts that may arise, which might result in a material risk to the interests of our clients.

Our approach has been to identify those aspects of our service, including how we interact with other companies within our Group and third-party suppliers, which could result in a conflict between your interests and ours, or between the interests of different clients.

We believe that our current organisational arrangements, systems and controls, provide an effective way of preventing your interests being unfairly affected. Here is a summary of the types of conflicts and the way we manage them.

Decision Criteria for Dealing

We have in place an allocation policy, which sets out the criteria by which client quotes are managed and promptly allocated to individual advisors. In addition, all client quotes are dealt with in a timely manner. No unfair priority is given to quote requests from other clients, colleagues, brokers or from other parts of our Group.

Confidentiality and Protection of Inside Information

We operate information barriers, which limit the flow of potentially price sensitive information between colleagues and different areas of our Group. Our internal dealing rules prevent colleagues in possession of price sensitive information from taking advantage of that information by dealing with the respective business or arranging for someone else to do so on their behalf.

Organisational Arrangements

The organisational structure we have implemented provides for the segregation of duties and so prevents conflict arising through inappropriately apportioned roles and responsibilities by ensuring that no one individual can exercise inappropriate influence over a particular process. Our management team operates independently from other Group companies and there are appropriate controls on cross-board membership.

If we were to acquire information that gave rise to a conflict of interest in a Group context, we would take steps to manage that conflict.

The dealing arrangements for personnel of key service providers can be relevant to our conflict management responsibilities. Potential conflicts are controlled in these circumstances through the use of contractual provisions together with regular monitoring of the dealing arrangements of the staff of these providers.

Personal Conflicts

Contracts of employment prevent colleagues from accepting roles or directorships with companies outside the Group, including those with whom we have commercial relationships unless prior approval has been received from the Directors.

We are mindful that a conflict may arise should colleagues have other business interests, which involve clients who are also Group clients, or which conflict with their duties to General and Medical Finance Ltd or the other Group companies.

A potential conflict may in theory also arise where our colleagues have friends and relatives who are clients of General and Medical Finance Ltd. To overcome this type of potential conflict we have specific internal controls and dealing arrangements, which also comply with FCA rules.

We do not show preference to any client, group of clients or clients who are also colleagues, over another in the provision of our services.

In addition to the above, colleague bonus and remuneration arrangements are carefully considered to ensure that conflicts do not inadvertently arise through inappropriately set targets.

Furthermore, an internal whistleblowing policy is in operation, which affords colleagues a high level of protection should they report any wrongdoing by others.

Selection of Suppliers

We prevent conflicts arising regarding the selection of suppliers by refusing to accept or pay fees, commissions and non-monetary benefits, which do not directly enhance the service, offered. Any personal relationships are disregarded in the selection of service providers, agents and brokers to prevent inappropriate selection.

Commission and Income Disclosure

Charges, which we apply to your trades, may be shared with other members of the Group or other third parties. We will not show details of any remuneration or sharing arrangements of this kind on your contract. We acknowledge that gifts and entertainment arrangements common in the industry may give rise to adverse influence. We address this by limiting the receipt of gifts/entertainment to those of a non-material nature.

This summary reflects our detailed Conflicts of Interest Policy that is in place to ensure fair treatment for our clients through the effective management of potential conflicts. We are not aware of any further material conflicts of interest.

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