Principles for the management of conflicts of interest

Golding Capital Partners GmbH only acts as a broker of the shares of Golding funds to professional clients and, insofar as the regulations in the respective country provide for this, to retail clients who can be classified as so-called semi-professional clients.

Golding Capital Partners GmbH will only forward applications to become a shareholder in a Golding fund to the Golding fund company. This is a consultancy-free service. Golding Capital Partners GmbH does not make any personal recommendations based on personal circumstances to clients in advance of the investment brokerage. The company does not have enough information about the financial condition of clients to examine their personal circumstances. In addition, the financial investments are presented in advertising communications only as suitable for a group of clients and not for the specific client.

Golding Capital Partners GmbH has established principles for the management of conflicts of interest, which specify the circumstances under which conflicts of interest may arise that may cause considerable damage to client interests and the measures taken to manage these conflicts of interest.

Identification of conflicts of interest

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

 

The following may particularly cause conflicts of interest:

  • Golding Capital Partners GmbH receives remuneration for advisory and other services from the management company of the Golding funds.
  • Golding Capital Partners GmbH or other companies of the group have business relationships with the fund managers of the target funds.
  • Employees hold positions in other companies (e.g. board of Golding funds).
  • 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 from the fund managers of the target funds.

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 Capital Partners GmbH has taken the following arrangements:

  • Separation of functions and duties.
  • Confidentiality areas (so-called “Chinese Walls”).
  • Performance-based compensation structure.
  • Transparent fee structures.
  • Transparent regulations for the allocation of assets (so-called “fair allocation policy”).
  • Code of conduct for private transactions by employees.
  • Code of conduct for the receipt and granting of presents.
  • 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 Capital Partners GmbH discloses the nature and origin of the conflicts of interest to the customers insofar as the measures taken are not sufficient to ensure, with reasonable confidence, to avoid the risks of damage to the interests of the Golding funds and their investors. The disclosure is meant to enable the customer 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 GmbH does not receive any remuneration from the clients. However, the company receives remuneration from the management company of the Golding funds for advisory and other services. Said remuneration depends – directly or indirectly – on the fund volume.
  • The employees of Golding Capital Partners GmbH 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.