Conflicts of Interest Policy
How Azari Capital identifies, discloses and manages interests that could affect impartial judgement.
What a conflict is
A conflict can arise when personal, financial, group, client, partner or portfolio interests could improperly influence a decision or appear to do so.
Early disclosure
Potential conflicts should be raised before the relevant decision, transaction or allocation whenever reasonably possible.
Assessment
The seriousness of a conflict depends on the decision, parties, economic interests, information asymmetry and available safeguards.
Management tools
Possible responses include recusal, independent review, information barriers, additional disclosure, altered decision rights, contractual protections or declining the activity.
Related parties
Operating knowledge from elsewhere in the Azari group can sharpen diligence, but it does not replace independent underwriting. Any relationship with another Azari company is assessed on its own economics, risks, governance and conflicts.
Allocation
Where more than one party may be eligible for an opportunity, the basis for allocation should be consistent with the relevant mandate and disclosed process.
Gifts and benefits
Benefits that could reasonably influence judgement or create an appearance of obligation should be avoided or handled under appropriate internal controls.
Records
Material conflicts and the steps taken to manage them should leave a durable record.
No universal cure
Disclosure alone does not resolve every conflict. Some situations require structural protection or a decision not to proceed.
Contact
Questions or concerns about conflicts can be directed to hello@azaricapital.com.