Practice 4A: Dealing with Conflicts of Interest

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

conflicts.

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