Legal

Conflicts of Interest Policy

Last updated: 10 September 2025

Our commitment

Banyantree Investment Group Pty Ltd (ABN 97 611 390 615, AFSL 486279) maintains arrangements to identify, manage, and—where necessary—avoid conflicts of interest that may arise in the course of providing financial services. We do this to meet our licence obligations and to protect clients’ interests.

What we mean by a conflict

A conflict of interest exists when our interests (or those of our people or related parties) could be perceived to compromise, or actually compromise, our ability to act fairly and in our clients’ best interests. Conflicts can be actual, potential or perceived, and can be personal, commercial or organisational.

Scope

This policy applies to Banyantree, our officers, employees and contractors, and to representatives acting on our behalf. It covers our research, portfolio and trading activities, client engagement, and operational decision-making. It should be read alongside our Privacy Policy, Complaints & IDR Policy, and any client or product documentation.

The framework we use

We maintain a conflicts management framework that follows three core steps:

  1. Identify conflicts—before they arise where possible, and promptly when they do.

  2. Assess and control conflicts—using one or more controls (avoid, segregate, restrict, supervise, disclose).

  3. Review and record—keep registers, test controls, and update arrangements.

How we identify conflicts

We look for conflicts at onboarding and throughout the life of a mandate or relationship, including when we:

  • set or change remuneration and incentives

  • accept benefits, gifts or hospitality

  • trade, allocate orders, or select brokers and service providers

  • produce or distribute research and insights

  • consider outside business interests or personal account dealing

  • receive unsolicited ideas (see “Trader Corner & unsolicited ideas” below)

  • access or share non-public information.

We maintain a Conflicts Register and require staff to disclose relevant interests and changes promptly.

How we manage conflicts (controls)

1) Avoid

We may decline to act, step aside, or cease to act where a conflict cannot be managed to an acceptable level.

2) Segregate & restrict

We use information barriers, role segregation and need-to-know access to reduce the risk of inappropriate influence or information flows (for example, between research and investment functions). Where inside information may exist, we apply restricted lists and trading halts as appropriate.

3) Supervise & approve

Higher-risk activities (e.g., personal account dealing, gifts over thresholds, new research publications, changes to incentive plans) require pre-clearance or Compliance sign-off. We keep auditable records.

4) Disclose

Where a residual conflict remains, we give timely, prominent and specific disclosure—through client documents, research notes, mandate letters, website notices or direct communications—so clients can make an informed decision.

Specific conflict areas & our standards

Remuneration & benefits

We structure remuneration to avoid incentives that could reasonably influence research views or trading decisions. We prohibit gifts or benefits likely to create a conflict and record permitted gifts/hospitality in a Gifts & Entertainment Register. We comply with requirements on conflicted and banned remuneration.

Research independence

Research and commentary must be prepared with integrity and independence. Analysts must disclose material interests and relevant relationships; Compliance may impose trading blackouts and require certifications of independence.

Personal account dealing (PAD)

Staff must pre-clear personal trades in relevant instruments, abide by restricted lists, holding periods and blackout windows, and never misuse confidential or inside information. Exceptions require Compliance approval.

Outside business interests (OBI)

Employees must disclose OBIs (e.g., directorships, advisory roles, family trusts) and obtain approval before commencing or changing an OBI. Conditions may be applied or approval withheld.

Broker, counterparty & vendor selection

We select brokers and vendors on objective criteria (execution quality, service, financial stability, cost), not on gifts or soft-dollar arrangements. Any third-party benefits are recorded and assessed for conflicts.

Order handling & allocation

Orders are placed and allocated fairly and promptly using consistent procedures. We do not permit front-running, misuse of client order information, or preferential allocations.

Corporate interactions & market soundings

Where we receive non-public information (e.g., wall-crossing or market soundings), we apply information barriers, update restricted lists and supervise subsequent activity.

Trader Corner & unsolicited ideas

Ideas submitted via Trader Corner are recorded on receipt. We assess them independently; sending an idea does notcreate any obligation for Banyantree and does not entitle the sender to compensation. If we wish to cite or attribute an idea externally, we will seek your written consent first. Submissions are treated confidentially within Banyantree and logged to help manage conflicts and provenance.

Roles and responsibilities

  • Board/Principals: set the tone, approve this policy, receive material conflict reports.

  • Responsible Managers & Compliance: maintain the framework, registers and training; advise on controls; monitor and report.

  • All staff & representatives: identify and escalate conflicts early; follow controls; complete training; keep records.

Registers, records & training

We maintain and review: Conflicts Register, Gifts & Entertainment Register, PAD records, restricted lists, attestations/certifications, and training completion. We run periodic training and sample-test controls as part of our compliance plan.

Escalation, breaches and reporting

Potential or actual conflicts must be escalated to Compliance without delay. If a conflict results in a reportable situation under the Corporations Act, we will comply with the applicable breach reporting regime, including timely reporting where required.

Review cycle

We review this policy at least annually, and earlier if our business model, products, or the regulatory environment changes.

Contact

Questions about this policy can be directed to info@banyantreeinvestmentgroup.com or your usual Banyantree contact.