Conflicts of Interest

Our obligation to you

The Financial Conduct Authority requires us to take all reasonable steps to identify, manage and, where necessary, disclose conflicts of interest, both between Cronos and you as our client and between our clients. Our overriding obligation is to act in your best interests. No commercial relationship or internal interest will be permitted to override that duty.

This document summarises the types of conflict we have identified and how we manage them. A copy of our full Conflicts of Interest Policy is available on request.

Conflicts we have identified

Remuneration and staff incentives. Cronos and its staff are paid for providing investment management services, so there is an inherent risk that portfolio decisions could be influenced by what benefits us rather than what is best for you. We manage this by making investment decisions solely on the basis of your mandate and your interests, and by ensuring no member of staff is paid in a way that creates an incentive to act against your interests.

Managing portfolios for several clients. We manage investments for a number of clients and may at times be buying or selling the same investment for different clients at the same time. We manage this by applying consistent, documented processes for portfolio management and trade execution that treat all clients fairly.

Relationships with adviser firms. Some clients are introduced to us by authorised adviser firms, and there is a risk that our wish to maintain those commercial relationships could influence how we treat the clients they introduce. We manage this by keeping our obligations to each client independent of the introducer relationship, so that introduced clients receive the same standard of service and the same priority as clients who come to us directly.

Platform and custody selection. Cronos selects the platform used to hold your investments, and there is a risk that the choice could be influenced by benefits to us rather than by what is best for you. We select platforms solely on the basis of service quality, security of assets and best execution, and we do not accept payments or other benefits from platforms in return for directing business to them.

Personal investment activity by our people. Our directors and staff may hold personal investment accounts, and their personal dealing could conflict with decisions taken for clients. We manage this through a personal account dealing policy that requires staff to obtain clearance before dealing and to disclose holdings that could give rise to a conflict.

Gifts and hospitality. We may be offered gifts, hospitality or other benefits by third parties such as fund managers or platforms. We do not accept any benefit that could influence our investment decisions or our conduct towards you. Minor benefits that are reasonable and incapable of impairing our duties are recorded in a register and reviewed by our Compliance Officer.

How we manage conflicts

• A conflicts of interest register, maintained and reviewed by our Compliance Officer, recording each identified conflict and the steps taken to manage it.

• A personal account dealing policy requiring staff to obtain clearance before dealing.

• An inducements policy prohibiting benefits that could impair our duty to act in your best interests.

• Organisational arrangements ensuring investment decisions are taken independently of commercial considerations.

• An escalation route requiring staff to report any actual or potential conflict to the Compliance Officer promptly.

Disclosure

Where a conflict cannot be managed adequately by the arrangements above, we will disclose its nature and source to you in writing before we act on your behalf. Disclosure is a last resort. Our primary approach is to manage conflicts out rather than to rely on telling you about them.

Further information

If you would like more information, or a copy of our full Conflicts of Interest Policy, please contact the Compliance Officer at East Wing, The Stables, Whinchat Hall, Skipwith Road, Escrick, York YO19 6EJ, or by email to compliance@cronos-im.com.

Cronos Investment Management Limited is authorised and regulated by the Financial Conduct Authority (FRN 1046308).