Conflict of Interest Policy Summary

Brunel always seeks to put our clients’ interests ahead of our own. Where possible, we avoid potential conflicts but, when these do arise, our priority is to achieve the best outcome for clients.

As an FCA-authorised investment manager, Brunel Pension Partnership Limited (Brunel) is required to have effective arrangements in place to ensure that all reasonable steps have been taken to prevent conflicts of interest (conflicts)from adversely affecting the interests of its clients.

The key means by which it achieves this are set out in its Conflicts of Interest Policy (the Policy), which is broadly summarised below. It is reviewed by the Head of Compliance at least bi-annually and material changes are approved by Brunel’s board.

The Policy applies to all persons involved in Brunel’s business, who receive training on the identification and management of conflicts in accordance with the Policy, both when they join Brunel and subsequently. The disclosure of any personal conflicts is also required at all meetings of the board or any of its committees.

In broad terms, Brunel manages conflicts by:

Training staff on the types of conflicts which may arise, including providing examples of such potential conflicts
Adopting specific policies on potential conflict situations that may arise through the possession of inside information, such as its Market Abuse & Insider Information Policy, Personal Account Dealing Policy and Gifts & Entertainment Policy
Requiring all staff to disclose conflicts immediately upon becoming aware of them
Setting out clear roles and responsibilities, both in relation to the Policy and the processes described within it
Maintaining a register of staff external interests to allow potential conflicts to be identified and avoided before they arise
Maintaining a register of instances of conflicts as they arise
Carrying out a rigorous assessment of any potential conflicts that are identified and adopting appropriate measures, including escalation where required, to avoid or minimise any actual conflicts, always putting clients’ interests first

Stewardship Conflict of Interest

We may vote or engage with companies in which our clients have commercial relationships. These activities are guided by our Stewardship Policy and Voting Guidelines which are reviewed at least annually, in partnership with our clients. We publish voting and engagement reports quarterly and disclose along with our policy advocacy on the Stewardship section of our website.

In undertaking these activities, the following conflicts may arise:

We may engage with or vote the shares of a company which has a strong commercial relationship, including as a service provider, with Brunel and/or our clients
We may engage with or vote shares of a company where staff own securities or have a personal relationship with senior staff members in a company
We may engage with a government or government body which is the sponsor or associate of the sponsor of one of our clients
We may vote on a corporate transaction, the outcome of which would benefit one client more than another
We may otherwise act on behalf of clients who have differing interests in the outcome of our activities

Brunel maintains policies and procedures that mitigate perceived or potential conflicts. A number of steps have been taken to reduce the risk of an actual conflict and to mitigate the impact of such conflict. This includes, but is not limited to:

Where any staff member recognises a potential conflict of interest with a company in which we are engaging or voting this is escalated to their line manager
We have adopted voting guidelines, in consultation with our clients which also allow for split voting in the event of a potential conflict
Where there is potential for a conflict arising over our approach to voting or engagement this is escalated to our CRIO and onwards to the CIO and CEO where required
Voting recommendations relating to mergers and acquisitions follow manager recommendations, however for a contentious merger or acquisition Brunel will direct the voting in line with our Stewardship Policy

Our policy on conflicts may be best understood by considering its impact in practice. In our Annual Stewardship and Outcomes report we will provide case studies to provide further explanation on where potential conflicts of interest have been managed to ensure we act in the best interest of our clients.