This document sets out the policy for avoiding or managing trustee's conflict of interest. Trustees have duties to the beneficiaries of the trusts that they administer. Therefore, it is important to guard against any actual or perceived conflict of interest and manage any actual or perceived conflict of interest
The policy applies to all trustees of the PENSION (the "Scheme"). It aims to describe the circumstances which may give rise to a conflict of interest that could be detrimental to the interests of the beneficiaries of the Scheme; the procedures for managing such conflicts; and maintaining a register of trustees’ interests at all times.
This policy is in accordance with the guidelines issued by the Pension's Regulator in relation to the managing of the trustee's conflict of interest.
A conflict of interest may be actual or perceived. It is important for the trustees to be aware of the situations that may result in a conflict of interest. This policy sets out the most common examples of conflict of interest to serve as a guide for the trustees when making a decision about/in relation to the Scheme to ensure the best interest of the beneficiaries of the Scheme.
A conflict of interest may arise where:
(a) a trustee’s personal or family interests and/or loyalties conflict with those of the Scheme, or there is a perception of this conflict.
(b) the trustee works for the same organisation in any capacity whether as an employee, a self-employed contractor or any comparable role.
(c) setting investment strategy and reviewing investment choices.
(d) dealing with the allocation of surplus.
(e) favoring one beneficiary over the other because one is a relative.
(f) choosing different scheme advisers.
The examples of conflict of interest listed hereinabove are not exhaustive. These examples are only indicative of the type of situations that may constitute a conflict of interest.
Regular training sessions on this policy will be provided to the trustees including any newly appointed trustees to ensure they are aware of the principles contained in this policy.
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