Important Information
III. Conduct & Compliance
Conflicts of Interest
BLACKSWAN HOLDINGS LIMITED maintains a written conflicts-of-interest policy. The policy applies to directors, employees, secondees, and connected parties of both the ADGM holding vehicle and the Polish execution platform.
Identification
- Personal account dealing in instruments related to opportunities reviewed by the firm.
- Director or shareholder positions in counterparties, advisers, or service providers.
- Cross-fund allocation, where the firm acts in respect of more than one vehicle.
- Gifts and entertainment received from or given to counterparties.
- Outside business interests of personnel.
Management
Identified conflicts are entered into a register reviewed at least quarterly by the board. Mitigation measures include information barriers, recusal from decisions, pre-clearance of personal trades, and where mitigation is insufficient, disclosure to affected investors before any decision is taken.
Disclosure
Where a conflict cannot be reasonably mitigated, written disclosure is made to affected investors and counterparties prior to the relevant transaction. The firm does not proceed with a transaction where disclosure has been declined or is impracticable.