Compliance

Identification of conflicts of interest

Golding Capital Partners has identified situations in which conflicts of interest between the company including its managers, employees and persons or companies directly or indirectly related to the company on the one hand and the customers clients on the other hand as well as between clients arise or could arise and which adversely affect the interests of the funds managed by Golding Capital Partners and their investors.

Conflicts of interest may particularly be caused by the following:

• Golding receives remuneration for financial services from the funds and other clients. 
• Golding provides financial services to the funds and other clients that have the same or similar investment policies.
• Golding has business relationships with the fund managers of the target funds as a part of the financial services.
• There are transactions between the funds managed by Golding.
• Employees make subjective decisions when analyzing investment assets (e.g. regarding the valuation of assets or ESG aspects).
• Employees hold positions in other companies (e.g. board of the funds managed by Golding).
• Employees receive material, non-public information.
• Employees are privately investing in the target funds.
• Employees receive a performance-based compensation.
• Employees receive presents and other contributions/donations.

Arrangements to manage conflicts of interests

Golding Capital Partners GmbH has taken adequate arrangements to identify conflicts of interest and to ensure, with reasonable confidence, that risks of damage to the interests of the Golding funds and their investors are prevented. The arrangements ensure that employees can appropriately carry out activities in which conflicts of interest arise and could affect the interests of clients. Golding Capital Partners GmbH expects its employees to endeavor to avoid conflicts of interest on a case-by-case basis and to always perform their financial services with due regard for client interests. 

In particular, Golding has taken the following arrangements:

• Separation of functions and duties
• Confidentiality areas (so-called “Chinese Walls”)
• Performance-based compensation structure
• Transparent fee structures
• Transparent, multi-stage investment process
• Transparent rules for the allocation of assets (so-called “fair allocation policy”)
• Transparent rules for transactions between the managed funds (so-called "cross fund deals policy")
• Transparent rules for the consideration of sustainability risks
• Transparent rules for exercising voting rights
• Principles for private transactions by employees
• Principles for the receipt and granting of presents (so-called “gift policy”)
• Principles to act honestly, fairly and professionally and in the best possible interests of the clients (so-called “code of conduct”)
• Internal control function
• Appointment of a compliance officer
• Complaint management
• Point of contact for whistle-blowers
• Careful selection and thorough training of personnel

Disclosure of conflicts of interest

Golding discloses the nature and origin of the conflicts of interest to the customers insofar as the arragements taken are not sufficient to ensure, with reasonable confidence, to avoid the risks of damage to the interests of the funds managed by Golding Capital Partners and their investors. The disclosure is meant to enable the clients to take a decision on an informed basis.

In the following cases, organizational arrangements taken might be not sufficient to ensure, with reasonable confidence, that conflicts of interests are managed to the full extent:

• As usual in the financial sector, Golding Capital Partners does not receive any remuneration from the clients. However, the company receives remuneration from the funds for financial services. Said remuneration depends – directly or indirectly – on the fund volume.
• The employees handling the marketing of the funds receive variable compensation in the form of bonus payments, which are not determined exclusively, but also under consideration of the agreed sales objectives.