1. Purpose
This policy describes how Luminar Invest Capital DMCC identifies, prevents, manages and — where residual risk remains — discloses conflicts of interest that may arise in the course of its wealth management activities.
2. Identified categories of conflict
- Between Luminar Invest and a client (e.g. proprietary positions)
- Between two or more clients (e.g. block allocations)
- Between a staff member and a client (personal account dealing)
- Between Luminar Invest and a service provider (research, custody, execution)
3. Preventive measures
- Zero retrocession policy. Luminar Invest does not accept inducements, kick-backs or trailing commissions from third-party product providers.
- Information barriers between the discretionary management desk and the research / corporate access teams.
- Personal account dealing rules requiring pre-clearance and minimum holding periods for all staff.
- Gifts and hospitality register with a hard cap above which approval is required from the Chief Compliance Officer.
- Allocation policy ensuring fair and proportional allocation of block trades across client portfolios.
4. Disclosure
Where a conflict cannot be reasonably avoided or managed, it is disclosed to the affected client(s) in writing before the relevant service is provided, with sufficient detail to allow an informed decision.
5. Governance
The conflicts register is maintained by the Chief Compliance Officer, reviewed quarterly by the Risk Committee and annually by the Board.