Strategic Capital’s (“SC”) policy for managing conflicts of interest is as follows.
In order to ensure that the interests of our CLIENTS are not unfairly impaired in relation to the business we conduct, SC shall appropriately manage transactions that may cause conflicts of interest in order to protect the CLIENTS and maintain their trust.
The Chief Operating Officer (COO) shall be appointed the person responsible for promoting the appropriate management regarding conflicts of interest.
SC shall identify and categorize transactions that may cause conflicts of interest in advance. We shall review such transactions periodically and on an as-needed basis. Types of transactions that may cause conflicts of interest include transactions in which the interests of a CLIENT conflict with those of other CLIENTS, and transactions in which the interests of a CLIENT conflict with those of SC.
SC shall assess what is causing the conflict of interest and shall take the appropriate measures according to the situation. In addition, SC shall strive to provide clear communication regarding the specific details of the conflicts of interest.
SC shall review the effectiveness and appropriateness of the management of conflicts of interest and strive to continuously improve based on the results of the review