Legal
Conflicts of interest policy
Draft — not yet in force — requires legal and compliance approval
This document is a placeholder drafted for internal review. It is not legal advice, is not final, and does not yet govern any relationship with Quantari. Final policies will be published before any service becomes available.
Purpose and status
This document is a framework draft prepared for internal review. It describes how Quantari intends to identify, prevent where possible, manage and disclose conflicts of interest in any future regulated service. It is not final, is not in force, and requires legal and compliance approval. Quantari offers no regulated service today, and the governance and staffing arrangements referred to below are not yet established.
Proprietary models
Quantari develops its own systematic, quantitative models. A conflict could arise between Quantari's interest in its proprietary technology and a client's interest in suitable, well-executed decisions. Quantari intends to manage this by acting in clients' interests within agreed guidelines and by not presenting its technology as guaranteeing any outcome.
Allocation between clients
Where more than one client could be affected by the same decision or transaction, a conflict could arise in how opportunities, orders and executions are allocated. Quantari intends to allocate fairly and on a documented basis, so that no client is systematically advantaged or disadvantaged. The detailed allocation method depends on the future service model.
Personal-account dealing and employee conflicts
Personnel could hold or trade financial instruments for their own account, creating potential conflicts with client activity. Quantari intends to adopt personal-account-dealing rules and related controls. The specific rules and the people they apply to are not yet established. [Personnel arrangements: pending.]
Group relationships and outside business interests
Relationships with any affiliated entities, and personnel's outside business interests or roles, could give rise to conflicts. Quantari intends to identify and manage such relationships and interests through disclosure and, where necessary, restriction. No such relationships are confirmed at this stage.
Third-party benefits and inducements
The receipt of any benefit from a third party — such as retrocessions, rebates or other inducements connected with providers or products — could conflict with a client's interests. Quantari's intended position on whether any such benefit could be received, and if so how it would be handled and disclosed, would be settled with the fee arrangements. No such benefit exists today. [Inducements: pending confirmed arrangements.]
Broker and provider selection
Selecting brokers, custodians, banks and other providers could involve conflicts, for example where a provider offers benefits to Quantari. Quantari intends to select providers on the basis of clients' interests and documented criteria. No providers are confirmed, so no selection has been made. [Provider selection: pending.]
Valuation and fees
How assets are valued, and how fees are calculated and applied, could create conflicts, for example where valuation affects a performance-related charge. Quantari intends to rely on independent valuation sources where possible and to make its fee basis transparent. The fee model is not yet approved.
Gifts and entertainment
The giving or receiving of gifts, hospitality or entertainment could improperly influence decisions. Quantari intends to adopt proportionate rules governing such benefits. The detailed thresholds and procedures are not yet established. [Gifts and entertainment rules: pending.]
Identification, disclosure and mitigation
Quantari intends to maintain a process to identify conflicts, to prevent or mitigate them through organisational and procedural measures, and — where a conflict cannot be sufficiently mitigated — to disclose it clearly to the affected client before providing the relevant service, so the client can make an informed decision.
Escalation and governance
Quantari intends to define how conflicts are escalated and decided, and to allocate responsibility for the policy and its operation. The governance bodies, roles and reporting lines that would carry this out are not yet established and will be described once they exist. [Governance structure: pending.]
Record keeping
Quantari intends to keep records of identified conflicts and of the measures taken to manage them, and to review the policy periodically. The retention periods and review cadence would follow applicable requirements and are not yet fixed. [Record-keeping detail: pending.]
Status: draft placeholder. Last updated: not yet published.