Conflicts of Interest Policy

TD & Partners Global manages conflicts of interest transparently so they do not compromise our independence, objectivity or the interests of our clients. We act in our clients' best interests and disclose and manage conflicts that arise.

A conflict of interest arises where our interests, or those of our people, could improperly influence — or appear to improperly influence — our judgement or actions in relation to a client or the firm. Conflicts may be actual, potential or perceived.

We encourage our people to identify conflicts early. Common situations include personal interests, relationships with client personnel, holding relevant financial interests, and acting for clients with opposing interests.

Where a conflict is identified, we disclose it to those affected promptly and clearly. Disclosure is not a substitute for appropriate management of the conflict.

We manage conflicts through measures such as informing the client, declining or withdrawing from work, restricting involvement, or implementing safeguards. We document significant conflicts and how they were managed.

Our people are expected to disclose personal interests and relationships that could create a conflict. We record and review these and take steps to address them.

In managing conflicts we respect client confidentiality and do not use one client's confidential information for another client's benefit.

Concerns about conflicts should be raised through our Speak Up and Whistleblowing Policy. We act on concerns and protect those who raise them in good faith.

We review this policy regularly. The effective date and version are shown on the policy page.