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interest policy
SECTION A: INTRODUCTION
Business activities & organisational structure of Barings
The Barings companies provide discretionary investment
management services. They also sell Barings funds and services
direct to institutional clients and through other professional
distributor firms.
Barings ultimate parent company is Massachusetts Mutual Life
Insurance Company. The principal intermediate Barings company is
Baring Asset Management Limited (BAML); which is the governing
body of Barings. The members of the Board of Directors and the
Management Committee of BAML are responsible for ensuring that:
(a) reasonable measures are taken to identify conflicts of interest;
(b) effective organisational and administrative arrangements are
maintained to prevent conflicts of interest from adversely affecting
the interests of Barings clients; (c) records are maintained of the
kinds of services/activities carried out by or on behalf of Barings in
which conflicts of interest entail, or may entail, a material risk of
damage to the interest of one or more clients.
Definitions of terms used in this Policy
Affiliated company: means Massachusetts Mutual Life Insurance
Company and its subsidiaries that are not part of Barings.
Barings: means BAML and its subsidiaries and Baring North
America LLC (but excluding Baring Asset Management Korea
Limited).
Barings Funds: means open-ended collective investment
schemes/mutual funds and closed end funds that are established,
sponsored and managed by Barings.
SECTION B
Segregation of duties
Potential Conflicts: Activities and roles of employees involved in
making investment decisions and/or monitoring investment
restrictions, investment risk or arranging execution of client trades
could present possibilities for such employees to favour or
disadvantage one or more clients and to gain financial benefits if
they were able to influence the selection of brokers/counterparties
without appropriate Controls.
Barings Controls: These are designed to ensure that clear
segregation of duties is maintained between employees and
processes involved in investment decision making and those
involved in monitoring investment restrictions, investment risk and
execution of transactions.
Trade Errors
Potential Conflict: Errors whilst trading (for example a breach of a
client investment restriction), may not be rectified promptly and the
client appropriately compensated to avoid a financial loss.
Barings Controls: Barings has established an Incident Reporting
policy which requires the prompt reporting and rectification of all
incidents (including trade errors). The policy requires that Barings
reimburse the client for any loss incurred. The Incident reporting and
investigation processes and controls in place ensure that clients are
not disadvantaged by any trading error made by Barings.
IMPORTANT INFORMATION
This document is issued by Baring Asset Management Limited,
authorised and regulated by the Financial Conduct Authority.
April 2016
www.barings.com