This page states Azari Holdings’ public policy position. Applicable law, contracts, regulatory requirements and more specific subsidiary procedures may impose additional or stricter requirements.
Identify conflicts early
Potential conflicts can arise through investments, family relationships, outside employment, gifts, supplier relationships, personal transactions, competing duties or access to non-public opportunities.
People should consider appearance as well as actual influence because undisclosed conflicts can damage trust even where the decision was technically fair.
Disclosure
A material conflict should be disclosed to an appropriate manager, governance owner or decision-maker before the affected person participates in the matter where practical.
Disclosure should include enough information to understand the nature of the interest without spreading unrelated personal details.
Management options
A conflict may be managed through recusal, independent review, changed responsibilities, information barriers, competitive procurement, divestment of an interest or another control appropriate to the circumstances.
Some conflicts cannot be managed adequately and may require the activity or relationship to be declined.
Customers and counterparties
Where an Azari company owes contractual, professional or regulated duties to customers or counterparties, conflicts should be handled in accordance with those more specific requirements.
A group relationship should not be used to steer a client to another Azari company where doing so would breach a duty or misrepresent the available choice.
Records and review
Material conflict disclosures and management decisions should be recorded well enough to support accountability and later review.
Conflicts can change over time, so continuing relationships may need to be reconsidered when roles, ownership or personal interests change.