Conflicts of interest policy summary

AMUNDSEN has written a policy to manage conflicts of interest and it has implemented specific provisions in terms of its organisation (means and procedures) and control to prevent, identify, and manage conflict of interest situations that could harm its clients’ interests.

However, if any conflicts of interest do arise, they will be managed in the client’s interest, meaning in an equitable manner, and the client will be provided with complete, adapted information.

It is hereby recalled that AMUNDSEN is an independent management company in the exercise of its activities.

Thus, AMUNDSEN authorises itself, in view of conflict-of-interest situations, to:

  • carry out the activity or transaction to the extent that the organisation allows for the appropriate management of the potential conflict of interest situation
  • inform the client if certain conflicts of interest may exist, and send him/her the necessary information regarding their nature and origin
  • not carry out the activity or transaction leading to a conflict of interest, if applicable.

AMUNDSEN must manage all conflicts of interest, from the moment of their detection to their appropriate handling. To this end, AMUNDSEN has set up an organisation for the:

  • prevention of the arising of conflicts of interest by educating all staff in the internal and external rules and codes of conduct and by implementing strict rules and procedures
    • implementation of an internal control system
    • separation of roles that might manage potential conflicts
    • constant assurance that the products and services that AMUNDSEN proposes to its clients in fact correspond to their profile and expectations and never contradict their interests
    • prohibition of personal transactions that do not follow the rules set by the company
    • training and awareness-raising among all staff in the profession’s best practices
  • identification of conflict-of-interest situations that may harm client interests by drawing up a map of the risks of such conflicts of interest. This map specifies the activities or operations in which a conflict of interest is likely to arise. AMUNDSEN’s CCO is responsible for updating this map


  • management of potential conflict of interest situations:
    • by informing clients in a complete, objective fashion, and by abstaining from using tendentious arguments and pointing out the constraints and risks associated with certain products or transactions
    • by requiring employees to report to the CCO all gifts and benefits received according to the rules established by the AMUNDSEN, as well as conflict of interest situations in which they may find themselves, as they arise.