Conflicts of Interest

At Howden (we/our/us), we always act in our clients’ best interests. This includes managing any conflicts of interest that do or may arise. To enable effective conflicts of interest management, we have in place a Conflicts of Interest Policy, oversight of actual and potential conflicts of interest by our Governance Forum and Board of Directors, and regular communication with and training for all our employees.

Our general approach to managing conflicts of interest includes:

• Controlling conflicts – Where possible, we will control conflicts of interest by implementing procedures to ensure that the affected party’s interests are not compromised as a result of the conflict.

• Disclosing conflicts – We will make disclosures to clients as part of our approach to managing conflicts of interest. At all times, we will ensure our clients are adequately informed about conflicts that may affect the provision of financial services to them.

• Avoiding conflicts – Where there is a material and fundamental conflict between our interests and the interests of a client, it may be necessary to avoid the conflict altogether. Where a conflict arises, it may be necessary to restructure the relationship or, if the conflict cannot be averted, not enter into it at all.

We will use our best endeavours to ensure that the quality of our service is not compromised by conflicts of interest and that our actions are transparent at all times, ensuring our services are provided efficiently, honestly, and fairly.

If you have any questions regarding how we manage conflicts of interest, please email us at [email protected].