Conflicts of Interest Policy and Inventory

Protean Capital LLP is a limited liability partnership in England and Wales (No. OC375671) and is authorised and regulated by the Financial Conduct Authority, with FRN: 593439. This Policy applies to Protean Capital LLP ("Protean"), the legal trading company that manages the products and services we offer to our customers.
This version of the Policy was updated on May 1, 2018.

Identification of Conflicts

Protean's Principals take responsibility for identifying and designing conflict management controls faced by Protean in its day to day business. Any conflicts are logged in a Conflicts Inventory. This inventory is periodically reviewed or updated when a new conflict is identified.

Conflicts Avoidance

Where a conflict is identified, Protean will seek to organise its business activities in a manner which avoids such a conflict. However, the avoidance of all conflicts is generally not feasible in a commercial environment.

Conflict Management

Where conflicts are unavoidable, Protean will take appropriate measures to mitigate and manage such conflicts in a manner that seeks to ensure that Protean or its Personnel are not advantaged, and that no Client is disadvantaged.

Conflicts Disclosure

Where Protean is not reasonably confident that it is able to manage a particular conflict to adequately protect the interest of a Client, the general nature and/or sources of conflicts of interest will be clearly disclosed to the Client before undertaking any business.

Conflict Monitoring

Protean has implemented a number of procedures and controls to detect conflict situations as they arise, and the Principals will update the Conflicts Inventory accordingly. Once conflicts have been identified, further procedures and controls monitor the effectiveness of the management arrangements of such conflicts.

In addition, Protean's compliance monitoring programme incorporates a number of tests aimed at reviewing its performance in the management of conflicts identified.

Education and Awareness

All Personnel receive a copy of Protean's Compliance Manual containing Protean's conflicts arrangements. In addition, all Personnel are required to give an undertaking of adherence to Protean’s compliance procedures, including personal account dealing and receipt of gifts and inducements.

All Personnel also receive both formal and informal training in respect of conflicts of interest generally, and on specific or potential conflicts to Protean.

How to contact us

If you have any questions about this Policy, please contact the Head of Compliance:

Arafat Shah,
Protean Capital LLP,
4th Floor Hazelwood House,
53 New Oxford Street,
London,
WC1A 1BL.