Legal Documentation

Conflict of Interest Policy

Last updated: 2026-03-27

1. Purpose

This summary sets out how Veridion Capital Management identifies, manages, and discloses conflicts of interest that may arise in the conduct of our business. This policy applies to all principals, staff, and associated persons of the firm.

2. What Is a Conflict of Interest?

A conflict of interest arises where the interests of Veridion Capital Management, its principals, or associated persons may diverge from the interests of an investor. This includes situations where the firm or an individual associated with the firm could benefit (financially or otherwise) at the expense of an investor, or where competing investor interests could disadvantage one party over another.

3. Identified Potential Conflicts

Veridion has identified the following categories of potential conflict:

  • Conflicts arising from the firm's relationship with third-party brokers and execution venues
  • Performance fee structures that may incentivise risk-taking beyond investor risk tolerance
  • Situations where principals may have personal trading accounts or interests in instruments used in managed strategies
  • Competing investor mandates that may result in allocation decisions affecting relative performance

4. Management of Conflicts

We manage conflicts of interest through the following controls:

  • Maintaining a Conflicts of Interest Register, reviewed periodically
  • Implementing information barriers where required
  • Requiring staff to disclose personal interests that may conflict with investor interests
  • Ensuring capital allocation decisions are made in accordance with documented strategy parameters rather than personal interest
  • Disclosing material conflicts to investors before or when they arise

5. Broker Relationships

Veridion Capital Management works with third-party brokers to execute investor mandates. The selection of brokers is based on execution quality, platform capabilities, and regulatory standing, not on commission or referral arrangements that would create a conflict with investor interests. Any material financial arrangements with brokers are disclosed in the Broker & Execution Disclosure.

6. Disclosure

Where a conflict of interest cannot be adequately managed through internal controls, we will disclose the conflict to the affected investor before proceeding. Disclosure is made in a manner that allows the investor to make an informed decision about how to proceed.

7. Contact

Questions or concerns about conflicts of interest can be directed to: compliance@veridioncapital.com.