This Conflicts of Interest Policy (the “Policy”) is intended to identify, record and prevent or manage conflicts
of interest fairly, both between the company and its customers and between a customer and another client.
Three Hills Capital (“THC” or the “Company”) is required to put into place systems and procedures designed
to prevent money laundering, the financing of terrorism and conflict of interests.
This Policy has applicability to conflicts between the Company and its customers and between a customer and
another client.
This Policy also applies to all THC employees and Officers.
3. Identification and Management of Conflict of Interest
3.1 The Company must take all reasonable steps to identify conflicts of interest between:
(i) The Company including its managers and employees or any person directly or indirectly
linked to them by control and a client of the firm; or
(ii) One client of the Company and another client; that arise or may arise in the course of the
firm providing any service.
3.2 For the purposes of identifying the types of conflict of interest that arise or may arise, in the course of
providing a service and whose existence may entail a material risk of damage to the interests of a client,
the Company must take into account as a minimum, whether the firm or a relevant person or a person
directly or indirectly linked by control to the Company:
(i) Is likely to make a financial gain or avoid a financial loss, at the expense of the client;
(ii) Has an interest in the outcome of a service provided to the client or of a transaction carried
out on behalf of the client which is distinct from the client's interest in that outcome;
(iii) Has a financial or other incentive to favour the interest of another client or group of clients
over the interests of the client;
(iv) Carries on the same business as the client; or
(v) Receives or will receive from a person other than the client an inducement in relation to a
service provided to the client in the form of monies, goods or services, other than the
standard commission or fee for that service.
3.3 The circumstances which should be treated as giving rise to a conflict of interest cover cases where
there is a conflict between the Company’s interests and the duty it owes to a client or between the
differing interests of two or more of its clients, to whom the firm owes a duty in each case. It is not
enough that the Company may gain a benefit if there is not also a possible disadvantage to a client or
that one client to whom it owes a duty may make a gain or avoid a loss without there being an associated
possible loss to another such client.
The Company must keep and regularly update a record of the kinds of service or activity carried out by or on
behalf of the firm in which a conflict of interest entailing a material risk of damage to the interests of one or
more clients has arisen or, in the case of an ongoing service or activity, may arise.
The Company must maintain and operate effective organisational and administrative arrangements with a view
to taking all reasonable steps to prevent conflicts of interest.
5.1 Disclosure of conflicts
If arrangements made by the Company to manage conflicts of interest are not sufficient to ensure with
reasonable confidence, that risks of damage to the interests of a client will be prevented, they must clearly
disclose the general nature and / or sources of conflicts of interest to the client before undertaking business for
the client;
(a) Be made in a durable medium; and
(b) Include sufficient detail taking into account the nature of the client, to enable that client to take an informed
decision with respect to the service in the context of which the conflict of interest arises.
5.2 The Company should aim to identify and manage the conflicts of interest arising in relation to their
various business lines under a comprehensive conflicts of interest policy.
5.3 All staff should avoid personal activities and financial interests which could conflict with their
responsibilities to the Company. They are to ensure that they exercise their powers and discharge the
duties of their offices honestly, in good faith and in the best interest of the Company, and not seek
gain for themselves or others through misuse of their positions.
5.4 In the event that the Company’s management determines that it is unable to manage a conflict of
interest, it may decline to act on behalf of a Client.
No individual may use, as an Officer, any information acquired during employment with the
Company, to make personal investments that may create a conflict, or the appearance of a
conflict, between the employee’s personal interests and those of the Company or of its
Clients.
Training on the Conflicts of Interest Policy and the handling of conflicts is provided to all relevant staff.
THC must monitor and keep a record of situations where conflicts of interest arise and it is for the Compliance Team to
maintain these records (the “Conflicts Register”). A record of the Conflicts Register will be maintained by the Compliance
Officer and it will contain the nature and form of the evidence obtained (for identification purposes) together with a copy
of the evidence. If no evidence is copied and recorded in the Conflicts Register then sufficient details, instructions and
general information will be recorded to enable THC to obtain a copy of the evidence if necessary and when required.
The Policy will be reviewed at least annually, or as necessary to keep pace with any changes. The most recent version of
this Policy will always be available on our website
