Conflicts of Interest Policy

Updated December 2024

Introduction

Managing and preventing conflicts of interest is an important part of running a fair and trustworthy financial services business. At Octopus, we’re committed to treating everyone fairly—our clients, partners, and employees. If we can’t completely avoid a conflict of interest, we make sure it’s handled in a way that protects the interests of everyone involved.

This document explains our conflicts of interest policy. It covers how we identify and prevent potential conflicts, how we manage them when they happen, and who is responsible for making decisions in these situations.

Conflicts of interest can happen in various ways, like when Octopus’ interests clash with those of a client, or when the interests of different clients or parts of our business don’t align. The same applies if an employee’s personal interests are at odds with the company’s or a client’s interests. Whatever the situation, this policy ensures we handle these matters transparently and fairly.

Understanding Conflicts of Interest

We always aim to act in the best interests of our clients, but there may be times when we or one of our other clients have a connection to the business being carried out.

For example, TW11 Wealth Management Limited and our chosen discretionary fund manager (DFM), Octopus Money Limited, are both part of the Octopus Group of companies and share the same owners. However, this connection doesn’t affect our responsibility to give impartial advice. You can trust that our recommendations are made with your best interests in mind.

Similarly, TW11 Wealth Management Limited and Octopus Money Limited use the services of Seccl, another company within the Octopus Group. Seccl operates the Octopus Money Platform, an administrative platform we may use to manage your investment portfolio. Again, this relationship doesn’t impact our duty to provide unbiased advice.

We’re transparent about these connections and include details in our terms of business so that you’re fully informed as part of the service we provide.

Managing Conflicts of Interest Transparently

At Octopus, we’re dedicated to identifying and managing any actual, potential, or perceived conflicts of interest. We have clear processes in place to prevent or address these situations, ensuring fairness and transparency for everyone involved.

Here’s how we manage conflicts of interest:

• Identifying conflicts: We use conflict management processes, insider lists, internal systems, and a register of outside business interests to spot any actual, potential, or perceived conflicts.
• Controlling information: We have strict controls on how we handle confidential and inside information to ensure it’s managed responsibly.
• Keeping clients informed: We disclose any potential conflicts to our clients early in the relationship so they’re aware from the start.

These steps help us maintain trust and act in the best interests of our clients at all times.

How We Manage Conflicts of Interest

Clear Policies and Training

We’ve developed policies, procedures, and training to help our team understand and manage conflicts of interest effectively. This ensures they can identify situations where a conflict might arise and take appropriate steps to prevent or manage it.

Information Barriers and Reporting Lines

To maintain independence and reduce the risk of conflicts, we segregate certain business functions and reporting lines where necessary. For example, we have independent Compliance and Audit functions that are separate from the main business operations.

Personal Account Dealing

Our employees follow strict rules about personal account dealing. These rules limit transactions in securities or derivatives for their own benefit or on behalf of others. Employees cannot trade in a company’s securities if it’s on the insider list or if the trade could negatively affect client interests.

Accepting Gifts and Financial Advantages

Employees are not allowed to accept or give inducements, privileges, or financial advantages beyond a set threshold without approval from our Compliance team. They are also prohibited from asking clients or business partners for personal benefits or accepting cash gifts in any amount.

Managing Conflicts of Interest

At Octopus, we are committed to managing conflicts of interest transparently and fairly. Here’s how we address these situations:

• Preventive measures: We apply robust policies, controls, and training to prevent conflicts where possible.
• Declining to act: If a conflict cannot be managed effectively, we may choose not to proceed.
• Disclosing conflicts: In rare cases, where preventive measures aren’t enough, we disclose conflicts to clients or affected parties, giving them the information they need to make informed decisions.

A Conflicts Committee oversees the identification and management of conflicts. The committee reviews proposals, monitors existing conflicts, and takes action where necessary. If further escalation is required, matters are referred to the Audit and Risk Committee or the Board.

Role of Compliance

The Compliance team provides neutral advice on managing conflicts to protect Octopus from legal, regulatory, or reputational risks. Compliance works closely with the Conflicts Committee and has the authority to raise issues directly.

Monitoring and Reporting

To ensure our approach remains effective:

• Compliance and Audit teams conduct regular reviews of our policies, procedures, and systems.
• Conflicts management is reviewed by the Conflicts Committee every six months, with oversight from the Audit and Risk Committee.

These steps help us maintain fairness, transparency, and trust with all stakeholders.