About This Practice
This guidance covers practice 4A which has three elements:
1. ⬤ Adopt a written conflict of interest policy that addresses, for all insiders, how conflicts are identified and avoided or managed.
2. ⬤ Document the disclosure and management of actual and potential
3. When engaging in any transaction with an insider:
a) Follow the conflict of interest policy.
b) Contemporaneously document that there is no private inurement.
⬤ Accreditation indicator element | ■ Terrafirma enrollment prerequisite | ▲ Required for both