It is the basic, underlying principle at PiP* that THE CLIENT ALWAYS COMES FIRST. The PiP Board(s) will not tolerate any behaviour that fails to adhere to this principle. Any breach of this principle will constitute gross misconduct and will be subject to disciplinary action.
PiP arranges its business to minimise the potential for any conflicts of interest to arise between different clients or between PiP and its clients. All employees receive a copy of the PiP Compliance Manual and related policies and are required to give an undertaking of adherence to them, including personal account dealing and receipt of gifts and inducements.
It is not possible, however, to avoid all conflicts and occasionally they do arise. Where conflicts are unavoidable, PiP will take appropriate measures to mitigate and manage such conflicts in a manner that seeks to ensure that PiP and its employees act in the best interests of its clients including its fund(s) or the investors in the fund(s).
In the first instance, the following procedures must be followed in any meetings or discussions involving PiP staff, whether external or internal:
- The Chairman, in consultation with other participants if appropriate, will determine whether any of the following actions should be taken:
- If you believe there could be any potential or real conflict of interest, resulting from the discussions taking place, whether real or perceived, this MUST be declared to the Chairman of the meeting, or in the absence of a Chair, the most senior PiP employee in the room.
- The potential conflict should be declared to all participants, but is not sufficiently serious to exclude the individual concerned from further involvement.
- The conflicted individual may remain in the meeting but may not contribute to discussions or decision making.
- The conflicted individual must leave the meeting and have no further involvement in discussions or decision making.
- Thereafter, the PiP Compliance Officer will investigate the concern and if there is an actual or potential conflict of interest the Compliance Officer will discuss this with the relevant person(s).
- If it is felt that the conflict of interest can be managed the Compliance Officer will implement the appropriate systems and controls to mitigate the risk;
- If the conflict of interest cannot be managed then the Compliance Officer and relevant person(s) will decide whether the conflict should be disclosed to clients, or if the activity causing the conflict should cease;
- Where disclosure is made, it must be in sufficient detail to enable the client to take an informed decision with respect to the service; and,
PiP is also aware that from time to time there may be potential conflicts of interest that do not involve external clients. These are likely to be the result of external interests of PiP employees. The PiP Board takes a similarly robust line on such potential conflicts:
- Immediate declaration once it becomes apparent that a potential conflict either exists or could be perceived to exist. Such declaration should be made to either a meeting Chair or the PiP Compliance Officer depending on circumstances.
- The Compliance Officer will investigate the potential conflict as described above.
A record of all declared conflicts of interest, and any agreed mitigation, will be maintained by the PiP Compliance Officer and regularly reported to the PiP Board.
PiP has identified the key conflicts (actual and potential) it faces in its day-to-day business. This inventory will be reviewed at least annually or updated when a new conflict is identified, with a report provided to senior management.
* PiP refers to Pensions Infrastructure Platform Limited and its subsidiaries including PiP Manager Limited