Conflicts Disclosure

Conflicts of Interest Disclosure Statement

1. Introduction

The MMPI Conflicts of Interest Disclosure Statement provides a summary of the Conflicts of Interest Policy adopted by MMPI Limited (“MMPI”, “the company”, “we”, “us”) that manages conflicts of interest in respect of the duties we owe to our clients.

2. Conflict Identification

For the purposes of identifying the types of conflict of interest that may damage the interests of a client or related party, MMPI monitors the areas of its business activities in which a material conflict has arisen in the past and could reasonably be expected to arise in the future.

3. Conflicts of Interest Policy

MMPI maintains procedures to safeguard its independence to act in the best interests of its clients at all times. These procedures extend to the physical separation of staff (as appropriate); the segregation of duties and responsibilities; reward and remuneration arrangements; personal account transactions; gifts and inducements rules that require and allow all MMPI employees to act in the best interests of the client and to identify and declare any and all conflicts of interest. In certain circumstances this may extend to declining to act for a client or potential client because of an identified conflict of interest.

MMPI is careful that its relationships with product and service providers, clients and other related parties are maintained on a professional basis and will not knowingly create situations that may give rise to a conflict of interest that may threaten its duty of care to its clients and its responsibilities to all related parties.

Where a conflict of interests arises and is unavoidable, it is company policy to fully advise the client (or related party) of the general nature and source of the conflict and to offer alternative arrangements, where appropriate. The advice will include sufficient detail, taking into account the nature of the conflict of interest, to enable that client (or related party) to make an informed decision with respect to the investment advice and/or ancillary service, in the context of which the conflict of interest arises.

4. Remuneration

MMPI is remunerated for its services by way a standard agreement with its clients (or related parties). MMPI has not entered into a soft commission agreement with any third-parties. These arrangements are designed to ensure that they do not compromise MMPI’s responsibilities to act in its clients’ best interests.

5. Gifts and Hospitality

MMPI takes reasonable steps to ensure that it or any of its officers or employees does not offer, give, solicit or accept any gifts or rewards (monetary or otherwise) likely to conflict with any duties or responsibilities of MMPI to its clients (or related parties).

January 2015