Conflict of Interest Policy
Last updated: April 25, 2025
Evermount Capital is committed to managing conflicts of interest fairly and transparently. This policy outlines how we identify, manage, and disclose potential conflicts of interest.
1. Policy Statement
Evermount Capital maintains policies and procedures to identify, prevent, manage, and disclose conflicts of interest that may arise between our interests and those of our clients, or between the interests of different clients. We are committed to acting in the best interests of our clients and maintaining the highest standards of integrity.
2. Types of Conflicts of Interest
Potential conflicts may arise from:
- Proprietary Trading: We may trade for our own account or related entities, which may conflict with client interests
- Fee Structures: Our compensation may create incentives that conflict with client interests
- Soft Dollar Arrangements: Receipt of goods or services from brokers or other service providers
- Related Party Transactions: Transactions with affiliates, related entities, or connected parties
- Information Barriers: Access to material non-public information that could benefit certain clients
- Allocation of Investment Opportunities: Deciding which clients receive access to limited investment opportunities
- Personal Trading: Personal investments by employees that may conflict with client interests
3. Conflict Management Measures
- Organizational Measures: Information barriers, separate reporting lines, and independent oversight functions
- Operational Measures: Separate management of different activities, separate accounts, and independent pricing
- Disclosure: Transparent disclosure of conflicts to affected clients where appropriate
- Policies & Procedures: Written policies and procedures for identifying and managing conflicts
- Employee Training: Regular training on conflict identification and management
- Monitoring: Regular review and monitoring of potential conflicts
- Personal Trading Policies: Restrictions on personal trading by employees
4. Disclosure of Conflicts
Where conflicts cannot be avoided or adequately managed, we will:
- Disclose the conflict to affected clients in a clear and timely manner
- Provide sufficient information for clients to make informed decisions
- Obtain client consent where required by applicable regulations
- Document all disclosures and client consents
5. Client Rights
Clients have the right to:
- Be informed of material conflicts of interest
- Receive clear and understandable disclosure of conflicts
- Make informed decisions about whether to proceed with transactions
- Request additional information about conflicts
- File complaints regarding conflict management