Article 20: Conflict of Interests and Disclosure Thereof

Article 20: Conflict of Interests and Disclosure Thereof

a) A fund manager (or any of its affiliates) may not act as principal for its own account when dealing with investment funds managed by it.

b) Without prejudice to the provisions of paragraphs (a), (c), (d) and (e) of this Article, the Fund Manager must treat any conflicts of interest in accordance with the provisions the Capital Market Institutions Regulations.

c) If the Fund Manager (or the fund sub manager) does not carry out a prior (where possible) or immediate disclosure of the conflict of interest to the relevant fund board, and obtain the fund board’s approval on that action, it must not engage in any action that involves:

1. A material conflict between the interests of the fund manager or fund sub manager and the interests of any investment fund it manages; or

2. A conflict between the interests of any investment fund it manages and another investment fund or another client account .

d) The fund manager (and fund sub manager), must ensure their affiliates do not engage in any action that involves any conflict of interest as described in paragraph (c) of this Article .

e) The fund manager shall disclose immediately, on its website and the Exchange’s website or any other website available to the public according to the controls set out by the Authority (where applicable), and on the public fund's annual reports that has been prepared by the fund manager in accordance with Article (26) of these Regulations, any conflicts of interest that has been approved by the relevant fund board