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- Gestión de Políticas de Interés-

The conflict of interest management policy of Klosters Capital (hereinafter, the "Policy"), together with its Internal Code of Conduct, aims to establish mechanisms that effectively prevent conflicts of interest that may arise between Klosters Capital and its clients or among its clients. Such conflicts could result in harm to the clients in the provision of investment services, as well as to effectively manage these conflicts of interest.

This Policy applies to: (i) members of the Board of Directors of Klosters Capital; (ii) employees whose work is directly or indirectly related to Klosters Capital's investment services activities; (iii) Agents, if any, providing investment services on behalf of Klosters Capital; and (iv) if applicable, companies subcontracted for an investment service (hereinafter, "Competent Persons").

A conflict of interest is deemed to arise when Klosters Capital or Competent Persons:

  • Stand to gain a financial benefit or avoid a financial loss at the expense of the client;

  • Have an interest in the outcome of a service provided to the client or an operation carried out on behalf of the client that is different from the client's interest in that outcome;

  • Have financial or other incentives to favor the interests of another client or group of clients over the interests of the first client;

  • Engage in the same activity as the client;

  • Receive or are to receive from a person other than the client an incentive in connection with a service provided to the client, in the form of money, goods, or services, apart from the usual commission or fee for that service.

The Policy establishes the measures and procedures adopted by Klosters Capital to identify conflicts of interest related to the provision of investment services and to identify scenarios in which conflicts of interest may potentially arise.

The Policy outlines the necessary measures to manage conflicts of interest identified by Klosters Capital. The purpose of these measures is to ensure that, in providing investment services to clients, Competent Persons can adhere to the general principles of honest, impartial, and professional conduct.

Finally, Klosters Capital's Policy includes relevant measures to prevent the flow of information between business areas that, according to current regulations, must act independently and separately.

Klosters Capital will maintain, in accordance with current regulations, an updated register of circumstances and investment services in which there is or may be a conflict of interest with a significant risk of harm to the interests of its clients. The Policy will be reviewed annually by the Compliance Unit.

In cases where the measures established to manage conflicts of interest are not, in the judgment of Klosters Capital, reasonably sufficient to avoid the risk of harm to the client, Klosters Capital must inform the client of the nature of the conflict and other circumstances that allow them to make a decision regarding the hiring of the investment service in the context in which the conflict of interest arises.

If a client requires additional information regarding any specific point of the policy, such a request will be directed to the Company.

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