Purpose and commitment

Northstake is committed to acting honestly, fairly, and professionally, ensuring that our services are always delivered in the best interests of our clients. This policy outlines how we identify, prevent, manage, and transparently disclose conflicts of interest

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Scope

This policy applies to:

• Northstake's management, employees, and any controlled or affiliated entities.
• Situations involving competing interests between Northstake and our clients, or between multiple clients whose interests may diverge.

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potential Conflict Scenarios

Conflicts may arise, for instance, when:

• Financial incentives could influence the selection or recommendation of services for the benefit of Northstake rather than the client.
• Relationships—such as personal, business, or shareholder ties—or group-wide roles might impair objective decision-making.
• Northstake serves clients with competing interests.

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Identification & Assessment

We maintain procedures to proactively identify conflicts of interest by evaluating:

• Financial incentives or remuneration structures
• Related-party transactions
• Client overlap or competing interests
• Internal relationships or affiliations that could influence neutrality

These procedures are periodically reviewed and updated—at least on an annual basis.

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Prevention & Management

Where conflicts are identified:

• We implement proportional and effective organizational structures, internal controls, and segregation of duties.
• In cases of heightened risk (e.g., multi-function intermediaries), more stringent measures—such as legal separation or independent oversight—may be deployed.
• Pre-clearance requirements apply to personal transactions by connected persons (with thresholds, reporting, and record-keeping).
• Remuneration policies are designed to avoid bias—ensuring that incentives align with client interests, not Northstake’s or individuals'.

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Roles & Oversight

Our management body is responsible for adopting, supervising, and reviewing this policy.

Adequate and independent resources (not limited to personnel, but including tools and systems) are provided for implementing and maintaining the policy.

We provide ongoing training to ensure staff are aware of conflict situations and reporting channels.

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Review & Continuous Improvement

At least annually, this policy is reviewed to ensure effectiveness. Any deficiencies identified are promptly addressed and corrected.