Conflicts of Interest Policy

Last updated: 5 August, 2026

Overview

This Conflict of Interest Policy is applicable to North Capital Management Ltd’s (NCM) Advisory, Discretionary and Execution Only services. This policy should be read in conjunction with the Firm’s standard terms of business. The Chief Operating Officer (COO) is responsible for this policy.

Introduction

We owe a duty of care towards to our customers and therefore have a responsibility to identify and actively manage conflicts of interests in a responsible way. Failure to do so may result in our not treating customers fairly and may harm our reputation.

Conflicts of interest may arise in one form or another.

This policy:

  • Provides guidance for employees;
  • Documents actual and potential conflicts that we are aware of;
  • Records details of individuals responsible for conflicts management;
  • Explains how to deal with and mitigate potential conflicts.

Please note however that while this policy aims to identify and list all potential conflicts, others may arise and therefore all employees must be able to identify a conflict and act appropriately.

Although the scope for conflicts of interest arising out of our business activities is limited, listed in the following sections are those that we have identified, with an explanation of how the conflict should be managed.

All employees must familiarise themselves with this policy and the procedures for managing them.

Definition

Broadly speaking, a conflict of interest can be defined as any situation where either the firm or an employee of the firm is in a position to exploit a sensitive situation, in a personal or official capacity, for either corporate or personal benefit.

NCM reviews its operations on a regular basis and has taken reasonable steps to identify and prevent or manage conflicts of interest that may arise between the company and its clients, between clients and between members of NCM employees and clients. This is not a definitive list but, as examples, there may be a conflict of interest where NCM (or anyone connected to us):

  • Are likely to make a financial gain (or avoid a loss) at the expense of a client; 
  • Are interested in the outcome of a service provided to a client where our interests are distinct from a client’s interests;
  • Have a financial or other incentive to favour the interests of one client over another;
  • Receive money, goods or services from a third party in relation to services provided to a client, other than the standard commission or fee for that service;
  • Be in competition with a client for the same type of business;
  • Recognise that a client is likely to make a financial gain (or avoid a loss) at the expense of another client; 

To help prevent and manage conflicts of interest, NCM has established policies and procedures which are designed to identify, prevent and manage conflicts of interest. Our specific policies and procedures relating to personal account dealing, gifts and inducements, order execution and order allocation which deal with potential and specific conflicts of interest are available upon request to clients.

Clients right to view our conflicts policy

Our Terms of Business states that “Our conflicts of interest policy is available for inspection upon request”. Should a client ask to see this policy there is a document included in our disclosure suite of documentation called “Our Conflicts of Interest Policy” (client handout) that can be used for this purpose.

Declining to Act

There may be some situations where it may not be possible for employees to act on behalf of a customer. In such circumstances, this should be referred to the person responsible for conflict management and NCM. (a Director or the COO)

How NCM identify a potential conflict

All employees are required to be familiar with the definition of a conflict of interest and understand how the reporting procedure works. Being familiar with this process forms part of the annual compliance sign-off by all employees. As with all procedures, employees are encouraged to seek clarification from their line manage if there is anything that is not understood. 

The board of NCM are committed to having an open and transparent risk culture across the business. This embedded approach to risk management enhances the effectiveness of the processes and is supported by a strong risk culture which encourages appropriate behaviours and collaboration across the business.  

This conflict of interest policy is reviewed regularly by the board of NCM and available on request to clients.

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