Last updated: September 2025
Identification of conflicts
- Conflicts of interest may arise between Metra and a client, between different clients, or between employees and clients.
- Examples include personal account dealing conflicts, preferential treatment of certain clients, or conflicts between proprietary activities and client interests.
- Metra maintains processes to identify actual and potential conflicts in its products, services, and organisational structure.
Management and mitigation
- Measures to manage conflicts may include segregation of duties, information barriers, independent oversight, restrictions on certain activities, or declining to act in particular circumstances.
- Employees are required to disclose personal conflicts of interest and to follow internal guidance on outside business interests and personal account dealing.
Disclosure of conflicts
- Where conflicts cannot be fully eliminated or mitigated, Metra may provide clear, fair, and non-misleading disclosure to affected clients so they can make informed decisions.
- Disclosure is not a substitute for effective internal management and is used in combination with other controls.
Governance and oversight
- Senior management and Compliance oversee the effectiveness of conflict of interest controls, including periodic reviews and updates.
- Conflicts and their treatment may be documented and recorded in accordance with regulatory and internal governance requirements.