Regulatory & Compliance·Updated 1 June 2026

Conflicts of Interest Policy

How Applique identifies, prevents, manages, and discloses conflicts of interest.

Purpose

Applique is committed to acting honestly, fairly, and professionally, and in the best interests of its clients. This policy describes how we identify and manage actual, potential, and perceived conflicts of interest that may arise in the course of our advisory and investment activities.

Identification of Conflicts

We assess conflicts that may arise between:

  • Applique and a client
  • Two or more clients of Applique
  • Applique's personnel and a client
  • Applique's own principal investment activity and an advisory mandate
  • A client and a related party, counterparty, or service provider

Management Measures

To manage identified conflicts, Applique applies measures including:

  • Information barriers between mandate teams where appropriate
  • Restricted lists and clearance procedures for personal transactions
  • Separation of duties and independent oversight
  • Mandate-specific engagement letters defining scope and remuneration
  • Pre-approval requirements for outside business activities and gifts
  • Periodic training and conflict reviews

Disclosure

Where organisational and administrative measures are not sufficient to ensure, with reasonable confidence, that a risk of damage to a client's interest will be prevented, we disclose the nature and source of the conflict to the client before undertaking the relevant business.

Record Keeping & Governance

Applique maintains a register of conflicts. The policy is reviewed at least annually and is approved by senior management.

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