Conflict of Interest Policy
Crestmont International is built on trust. Our Conflict of Interest Policy sets out the standards, processes, and obligations that ensure every decision we make is free from undue personal or financial influence — protecting our clients, our partners, and our reputation.
Integrity is the Foundation of Every Relationship We Build
At Crestmont International, our ability to serve clients, partners, and communities depends entirely on the trust they place in us. That trust is earned and maintained through rigorous ethical standards applied consistently at every level of our organisation.
This policy applies to all directors, officers, employees, consultants, advisors, and any person acting on behalf of Crestmont International or any of its group entities — including Crestmont Energy, Crestmont Real Estate, Crestmont Access, and the Fund for Nature.
Conflicts of interest are a natural feature of any complex investment advisory business. Our policy does not seek to eliminate them entirely — rather, it establishes clear obligations to identify, disclose, manage, and where necessary, avoid them.
Transparency First
We require proactive disclosure of any interest, relationship, or circumstance that could influence — or appear to influence — professional judgement.
Client Interests Are Primary
In all advisory and investment decisions, client interests take precedence over personal or institutional gain. No exceptions.
Accountability & Oversight
Conflicts are reviewed by independent governance structures. No individual decides alone on matters in which they have a declared interest.
Safe Reporting Channels
We maintain confidential, non-retaliation-protected channels for reporting concerns about conflicts or potential breaches of this policy.
Purpose & Scope
Purpose. This Conflict of Interest Policy (“Policy”) establishes the framework by which Crestmont International and all entities operating under the Crestmont International Group identify, disclose, manage, and where necessary, prohibit activities and relationships that create, or could be perceived to create, a conflict between personal interests and the interests of clients, investors, partners, or the firm.
Scope. This Policy applies to all Covered Persons, defined as any individual who:
- Is employed by, contracted by, or serves as a director or officer of Crestmont International or any of its subsidiaries or affiliated entities;
- Provides advisory, consulting, or professional services under mandate from Crestmont International;
- Serves on any board, committee, or governance body established by or for Crestmont International or its group entities;
- Has access to material non-public or commercially sensitive information about clients, transactions, or strategies.
This Policy applies across all Crestmont International business lines including Crestmont Energy, Crestmont Real Estate, Crestmont Access, and the Fund for Nature. Where local laws impose stricter standards, those standards shall apply.
Definitions
A situation in which a Covered Person’s personal, financial, or professional interests — or those of a connected party — could influence, or could reasonably be perceived to influence, the performance of their duties to Crestmont International, its clients, or its investors.
Any direct or indirect financial stake, beneficial ownership, loan, guarantee, contractual entitlement, or other economic arrangement that could influence or appear to influence professional judgement. Includes interests held by connected parties.
A spouse, civil partner, minor child, parent, sibling, or any entity in which the Covered Person holds, directly or indirectly, more than a 5% ownership interest, or over which the Covered Person exercises significant influence or control.
The confidential, centrally maintained register administered by the General Counsel in which all declared conflicts of interest are recorded, assessed, and tracked for management and resolution.
The formal withdrawal of a Covered Person from any decision, discussion, vote, or advice-giving process in relation to a matter in which a conflict of interest has been identified and declared.
Types of Conflicts of Interest
Conflicts of interest arise in many forms across an investment advisory and asset management business. The following categories are illustrative and not exhaustive. Covered Persons should apply the underlying principle — not merely the enumerated examples — when assessing whether a conflict exists.
| Conflict Type | Description | Risk Level |
|---|---|---|
| Personal Financial Interest | Holding a direct or indirect financial stake in a client, counterparty, or transaction in which Crestmont is also engaged. | High |
| Outside Employment & Board Seats | Serving as a director, officer, employee, or advisor to any entity that has, or may have, a commercial relationship with Crestmont International or its clients. | High |
| Connected Party Transactions | Facilitating or recommending business arrangements in which a Connected Party stands to benefit financially. | High |
| Gifts & Hospitality | Receiving gifts, hospitality, entertainment, or other benefits from clients, counterparties, or intermediaries beyond permitted thresholds. | Medium |
| Preferential Information Access | Using material non-public information gained through a professional relationship for personal benefit or to benefit a Connected Party. | High |
| Co-Investment Arrangements | Personally co-investing alongside clients or investors in transactions arranged or advised upon by Crestmont without full disclosure and approval. | High |
| Referral Arrangements | Receiving or paying referral fees, finder’s fees, or other compensation arrangements in connection with the introduction of clients or transactions. | Medium |
| Personal Relationships | Supervisory, evaluative, or commercial relationships with close personal associates where objectivity may be compromised or perceived to be compromised. | Low–Medium |
Disclosure Obligations
Proactive Disclosure. All Covered Persons are required to proactively disclose any actual, potential, or perceived conflict of interest to the General Counsel — whether or not they believe the conflict is material, and whether or not they believe it will affect their conduct.
Disclosure must be made as soon as the Covered Person becomes aware of the conflict, and in any event before the Covered Person participates in any decision, transaction, or communication to which the conflict is relevant.
The threshold for disclosure is low. If a Covered Person is uncertain whether a situation constitutes a conflict, they should err on the side of disclosure. The General Counsel will assess and advise on next steps.
Annual Declaration. All Covered Persons are required to complete an Annual Conflict of Interest Declaration, confirming the accuracy of any previously declared interests and disclosing any new interests or relationships arising during the year. The Annual Declaration cycle runs from January to March each year.
Ongoing Obligation. Disclosure is not a one-time obligation. Covered Persons must update their declaration immediately whenever circumstances change — including acquiring a new financial interest, accepting a board seat, entering into a new business relationship, or becoming aware of a potential conflict involving a Connected Party.
- Submit a written disclosure to the General Counsel using the designated Conflict of Interest Disclosure Form.
- Provide sufficient detail to allow a complete and accurate assessment — including the nature of the interest, the parties involved, and the transaction or matter to which it relates.
- Await written acknowledgement and any guidance from the General Counsel before proceeding with the relevant activity.
- Comply with any management measures specified by the General Counsel or the Ethics & Compliance Committee, including recusal if required.
Management & Controls
Upon receipt of a conflict of interest disclosure, the General Counsel will assess the nature and severity of the conflict and determine the appropriate management response. Management measures may include one or more of the following, applied proportionately to the risk level of the identified conflict:
- Recusal: The Covered Person is required to withdraw from all discussions, decisions, and communications relating to the matter in which the conflict arises.
- Information barriers: Structural restrictions are put in place to prevent the sharing of confidential information between teams or individuals where a conflict exists.
- Enhanced supervision: Additional oversight is applied to the relevant activity, transaction, or advice — including independent review by a senior officer not involved in the matter.
- Consent disclosure to client: Where the conflict cannot be eliminated and client interests may be affected, the conflict is disclosed to the relevant client in writing and their informed consent is sought before proceeding.
- Declination: In situations where no satisfactory management measure can be applied, Crestmont International will decline to act in the relevant capacity or withdraw from the transaction entirely.
All disclosed conflicts and the management measures applied are recorded in the Disclosure Register. The Register is reviewed quarterly by the Ethics & Compliance Committee and reported to the Board annually.
Prohibited Activities
The following activities are prohibited for all Covered Persons, regardless of whether a disclosure has been made. These prohibitions are absolute and may not be waived by the General Counsel alone — any exception requires Board-level approval, which will be granted only in exceptional circumstances:
- Trading in the securities of any client or counterparty while in possession of material non-public information obtained through a professional relationship with Crestmont International.
- Personally investing in, or directing a Connected Party to invest in, any transaction that Crestmont International is actively advising on or managing, without prior written approval from the Board.
- Accepting any gift, payment, loan, or benefit from any client, counterparty, government official, or third party that could reasonably be perceived as an inducement to act otherwise than in the best interests of clients or the firm.
- Using Crestmont International’s name, relationships, or confidential information for personal advantage or for the benefit of a Connected Party.
- Directing or influencing the allocation of investment opportunities, mandates, or contracts in favour of a counterparty in which the Covered Person or a Connected Party has an undisclosed financial interest.
- Retaliating against, or facilitating retaliation against, any person who makes a good-faith report of a potential conflict of interest or compliance concern.
Roles & Responsibilities
Effective conflict of interest management is a shared responsibility. The following roles carry specific obligations under this Policy:
| Role | Key Responsibilities |
|---|---|
| All Covered Persons | Proactive disclosure; completion of Annual Declaration; compliance with management measures; obligation to seek guidance when uncertain. |
| Line Managers | Creating an environment where disclosure is encouraged; escalating concerns to the General Counsel; ensuring team members are aware of this Policy. |
| General Counsel | Receiving and assessing disclosures; maintaining the Disclosure Register; advising on management measures; reporting to the Ethics & Compliance Committee. |
| Ethics & Compliance Committee | Quarterly review of the Disclosure Register; oversight of complex or elevated-risk conflicts; escalation to the Board where required. |
| Board of Directors | Setting the ethical tone at the top; approving any exceptions to prohibited activities; annual review and approval of this Policy. |
| Senior Leadership | Modelling the expected standards; participating in training; disclosing their own conflicts promptly and fully; supporting a culture of accountability. |
Reporting & Enforcement
Reporting Concerns. Any Covered Person who becomes aware — or reasonably suspects — that another person has failed to disclose a conflict, or has acted in breach of this Policy, is expected to report their concern. Reports may be made to the General Counsel directly, or through Crestmont International’s confidential compliance reporting channel.
Non-Retaliation. Crestmont International strictly prohibits any form of retaliation against a person who makes a good-faith report under this Policy. Any individual found to have engaged in retaliation will be subject to disciplinary action, up to and including termination of employment or engagement.
Consequences of Breach. A breach of this Policy — including failure to disclose, failure to comply with management measures, or engaging in a prohibited activity — is a serious disciplinary matter. Depending on the nature and severity of the breach, consequences may include:
- A formal written warning recorded on the Covered Person’s personnel file;
- Suspension from involvement in specific transactions, clients, or business lines;
- Requirement to divest a financial interest giving rise to a conflict;
- Termination of employment or professional engagement;
- Referral to relevant professional regulatory or law enforcement bodies where required by law.
Policy Review. This Policy is reviewed annually by the General Counsel and approved by the Board of Directors. Ad hoc reviews will be conducted as needed in response to material changes in the firm’s business, regulatory environment, or identified compliance concerns.
For any questions about this Policy, or to make a disclosure, please contact the General Counsel’s office through the Working With Us page, or visit our offices to speak with a member of the compliance team in person.
Ethics are Not a Compliance Exercise — They are Who We Are
Our Conflict of Interest Policy is one part of a broader governance framework that underpins every decision we make. It sits alongside our Anti-Bribery and Corruption Policy, our Data Protection Framework, our ESG Investment Standards, and our whistleblowing protections — all designed to ensure that Crestmont International remains a firm our clients, partners, and communities can trust unconditionally.
We hold ourselves to these standards not because regulators require it, but because our entire value proposition rests on being a trusted partner in some of the world’s most complex investment environments.
Anti-Bribery & Corruption
Zero tolerance for bribery in any form across all jurisdictions where we operate — applied rigorously to employees, agents, and intermediaries alike.
Data Protection & Confidentiality
Strict controls governing the handling of client data, transaction information, and commercially sensitive materials across all platforms.
ESG Investment Standards
Environmental, social, and governance considerations are embedded into every investment decision — not as a label, but as a genuine analytical framework.
Whistleblowing Protections
Fully protected, confidential channels for raising concerns — no retaliation, no exceptions, with direct access to the General Counsel and the Board.
Making a Disclosure is Simple
We have designed our disclosure process to be clear, accessible, and free of stigma. If you are a Covered Person and need to declare a conflict — or if you have concerns about a potential breach — here is what to do.
Identify the Potential Conflict
Review Section 3 of this Policy and apply the guiding principle: would a reasonable, informed person see this situation as capable of influencing your professional judgement? If yes, proceed to disclosure.
Contact the General Counsel
Submit a written disclosure using the Conflict of Interest Disclosure Form, available from the Legal & Compliance team. You may also raise the matter verbally in the first instance, but written confirmation will be required.
Get in touchAwait Assessment & Guidance
The General Counsel will acknowledge your disclosure within two business days and provide written guidance on the management measures to be applied — typically within five business days for routine disclosures.
Comply & Update
Follow all management measures. Update your disclosure immediately if circumstances change. Your declaration will be reviewed as part of the annual cycle each January.
Contact the Compliance Team
All disclosures and compliance concerns are handled with strict confidentiality by the General Counsel’s office. You will not face adverse consequences for making a good-faith disclosure.
Questions About Our Governance Standards?
Our compliance team is available to answer questions from clients, investors, partners, and prospective employees about our ethical standards, governance framework, and how we manage conflicts of interest across our business.