Conflicts & Ethics Protocols
We design conflicts of interest management frameworks and ethics protocols for investment organisations — ensuring that every potential conflict is identified, disclosed and managed before it becomes a governance failure.
Protocols Scope
- Conflict of interest register & identification
- Disclosure obligations framework
- Recusal & abstention procedures
- Related-party transaction oversight
- Gifts, hospitality & entertainment policy
- Whistleblowing & escalation framework
Our Advisory Services
Conflict Identification Framework
A systematic process for identifying actual, potential and perceived conflicts of interest — across investment decisions, business development, personal holdings and external appointments.
Disclosure Register
A documented conflicts register — maintained, updated and reviewed at defined intervals — with clear disclosure obligations to investors, counterparties and regulators.
Recusal Procedures
Documented procedures for recusal and abstention — who decides, how it is recorded, and how decision-making proceeds in the absence of the conflicted party.
Related-Party Transactions
Oversight framework for transactions with related parties — approval authority, independent valuation requirements, documentation standards and LP/board disclosure obligations.
Gifts & Hospitality Policy
Policy governing the giving and receiving of gifts, hospitality and entertainment — with thresholds, approval requirements and documentation obligations that satisfy regulatory and LP expectations.
Whistleblowing Framework
A confidential escalation channel for concerns about conflicts, ethical breaches or policy violations — designed to encourage early reporting and protect those who raise concerns.
Built for Real Outcomes
Conflicts of interest are not inherently wrong — they are a normal feature of any investment business. The failure is not having the conflict. The failure is not managing it.
Our protocols create the systems that ensure conflicts are surfaced, documented and resolved — before they damage investor trust or attract regulatory scrutiny.
Organisations That Need This Framework
- Investment fund managers — PE, VC, hedge fund
- Family office advisory boards
- Corporate investment committees
- Real estate investment managers
- Any organisation with LP/investor accountability
Conflict Categories We Map
- Principal trading vs client interests
- Co-investment alongside fund portfolio
- Cross-fund transactions
- Manager fee structures vs LP returns
- Personal account dealing by investment staff
Regulatory Context
- DFSA & ADGM conduct requirements
- FCA SYSC conflict management rules
- SEC investment adviser conflicts
- ESMA MiFID II conflict obligations
How We Work
Conflict Mapping
We systematically identify all potential conflict categories across your organisation and activities.
Framework Design
We design disclosure, recusal, register and escalation frameworks appropriate to your structure.
Policy Documentation
We produce all policies — conflicts, gifts, whistleblowing, related-party transactions.
Training & Embedding
We advise on how to train your team and embed the protocols in day-to-day operations.
Frequently Asked
Ready to Build Your Conflicts & Ethics Framework?
Our team designs protocols that are proportionate, documented and embedded — protecting your investors and your reputation.