Conflicts of Interest Policy Summary

Mitchell & Mitchell Asset Management Ltd (MMA)

1. Purpose

This policy sets out how Mitchell & Mitchell Asset Management Limited ("MMA") identifies, prevents, and manages conflicts of interest to ensure that we always act in the best interests of our clients. In accordance with FCA Principle 8, SYSC 10, the MIFIDPRU Remuneration Code, and the Consumer Duty, we are committed to:

  • Ensuring all clients are treated fairly and consistently

  • Managing conflicts that arise between:

    • MMA and its clients

    • One client and another

    • MMA’s staff and clients

  • Maintaining a culture of integrity and transparency

2. Identifying Conflicts

We identify conflicts that could arise from situations where MMA or a related person:

  • Could make a financial gain at the expense of a client

  • Has a competing interest in the outcome of a service

  • Receives an inducement from a third party (e.g. gifts, fees, or commissions)

  • Is in a position to favour one client over another

  • Is involved in both product development and pricing

We also consider conflicts that may arise from our ownership structure and relationships with other businesses within the wider GSI group.

3. Key Areas of Conflict

MMA recognises that conflicts of interest may arise in several core areas of its business. These include, but are not limited to:

🔹 Personal Account Dealing

Staff must obtain approval before undertaking personal investments and are prohibited from using confidential client or firm information for personal gain.

🔹 Gifts & Inducements

All gifts, hospitality, or inducements must be declared and recorded. We do not permit benefits that could impair objective decision-making or create undue influence.

🔹 Client Orders & Execution

Although MMA provides trading instructions, execution is carried out by authorised platforms. We do not hold client money or act as an execution venue, reducing conflicts around trade timing and allocation.

🔹 Segregation of Duties

Internal controls ensure that individuals cannot complete end-to-end functions without oversight. This supports both accuracy and the prevention of misuse or error.

🔹 Group Structure and Common Ownership

MMA is under common ownership with GSI Capital Limited, a separate company within the wider corporate group. While MMA operates independently — with its own regulatory permissions, governance, and discretion — shared ownership presents a potential source of conflict.

To mitigate this:

  • MMA maintains full autonomy over investment decisions

  • Oversight and resource-sharing (if any) are conducted on arms-length commercial terms

  • Any material connections are disclosed to clients where relevant

4. Managing Conflicts

We manage conflicts using a combination of:

  • Structural controls (segregation of functions, hierarchy, and oversight)

  • Procedural controls (staff declarations, approval processes, and registers)

  • Information barriers (“Chinese Walls”) to limit the flow of sensitive information

  • Disclosure — where a material conflict remains, we provide clear, written disclosures to the client

Where a conflict cannot be effectively managed or mitigated, MMA may decline to act.

5. Disclosure

If a conflict cannot be avoided or sufficiently mitigated, MMA will disclose to the client:

  • The nature and source of the conflict

  • The steps taken to manage it

  • The potential impact on the client’s interests

  • The option to proceed or withdraw

This will be provided in writing, and the client’s informed consent will be sought before continuing.

6. Review & Governance

  • This policy is reviewed at least annually or following any material changes to our business or regulation

  • All staff are trained annually on this policy and required to confirm their understanding

  • MMA’s senior management is responsible for oversight, review, and ongoing compliance with this policy

7. Contact

If you would like further information about how conflicts are managed at MMA, please contact:
Mitchell & Mitchell Asset Management Limited
1 Churchill Court, Horton’s Way, Westerham, Kent TN16 1BT
📧 enquiries@mmassets.co.uk
📞 +44 (0)1959 561500

Version: May 2025
Approved by: MMA Board of Directors
Next Review: May 2026 or upon regulatory update