Effective Date: April 13, 2025
Last Updated: April 13, 2025
1. Purpose
ASP Asset Management AIFP SIA, a licensed alternative investment fund manager (AIFM) registered in the Republic of Latvia, is committed to acting in the best interests of its investors and maintaining the highest standards of integrity. This Conflict of Interest Policy outlines how we identify, manage, and prevent conflicts of interest that may arise in the course of managing alternative investment funds.
2. Scope
This policy applies to all employees, directors, and associated parties of ASP Asset Management AIFP SIA involved in activities that may give rise to actual or potential conflicts of interest with the company, the funds it manages, or its investors.
3. Identification of Conflicts of Interest
Conflicts of interest may arise in situations where:
- The company or its employees have an interest in a transaction that conflicts with the interest of a fund or its investors;
- The company manages multiple funds with competing interests;
- An employee has a personal interest in an investment decision;
- The company receives benefits from third parties related to services provided to the funds.
4. Management and Mitigation
To manage conflicts of interest, we apply the following measures:
- Segregation of duties: Clear separation of responsibilities across functions and teams;
- Disclosure: Where appropriate, disclose conflicts to investors before undertaking relevant activities;
- Internal controls: Policies and procedures to monitor and manage potential conflicts;
- Independence: Staff members involved in decision-making must act independently and in the interest of investors;
- Record keeping: Maintain a log of identified conflicts and actions taken.
5. Disclosure to Investors
If a conflict of interest cannot be effectively managed by internal controls, ASP Asset Management will disclose the nature of the conflict and the steps taken to mitigate it to the relevant investors before proceeding with the activity.
6. Ongoing Review
This policy is reviewed and updated regularly to ensure it remains effective and in line with legal, regulatory, and industry standards.
7. Contact
For more information about our Conflict of Interest Policy, please contact:
ASP Asset Management
Address: Elizabetes Str. 63-2, Riga, LV-1050, Latvia
Email: ansis.spridzans@spridzans.lv
Phone: +371 29274672