Conflict of interest management

GRI 2-15

We take measures to prevent any conflicts of interest, as we recognise their potential impact on decision-making processes. For this purpose, we have implemented a Conflict of Interest Management Policy, which defines the procedure for preventing, identifying and managing conflicts of interest, as well as the procedures for interaction and coordination of the Fund's bodies and/or persons in the event that a conflict of interest arises or is likely to arise. All employees, as well as Directors, are aware of their obligations and responsibilities in relation to conflicts of interest and fully adhere to the Conflict of Interest Management Policy in force in the Fund.

We require our employees and directors to make full and timely disclosure of any actual or potential conflicts of interest. The Board of Directors and the Management Board monitor and seek to address potential conflicts of interest at the officer level.

The Fund has effective monitoring mechanisms in place to ensure compliance with the conflict of interest policy. In the event of a conflict of interest, the Fund has clear procedures in place to allow individuals to recuse themselves from decision-making processes where their personal interests may jeopardise their objectivity. In such a situation, alternative decision-making mechanisms help us to preserve the integrity of the process and prevent conflicts from affecting outcomes.

In 2024, no conflicts of interest were identified in the Fund as a result of a compliance service review.