conflict of interest management policy

According to the regulation of the European Financial Directive MIFID, Hugau Gestion has developed an intern policy of prevention and management of conflicts of interest to ensure the protection and the primacy of the interests of its customers.

This dispositive is composed by :

1) procedures to prevent the occurrence of such conflicts:

- Protecting the flow of confidential information

- Ensuring the objectivity of employees and equality of treatment between customers

- Conducting a regular census of potential risks that may affect the interests of clients on the occasion of the provision of an investment service

2) Regular training of Hugau Gestion employees who are informed and aware of these issues and must fulfill a commitment to compliance with the procedure for the prevention and management of conflicts of interest.

3) The establishment of a register of conflicts of interest. The compliance officer on this point is empowered to manage any rise to conflicts of interest and may at any time notify the general direction of the management company

4) The establishment of a mapping of potential conflicts of interest.This mapping of potential conflicts of interest is updated on a regular basis. It consists in an inventory of the various conflicts of interest that may arise internally, the associated risks and the measures to be taken.

5) A client information device if despite these precautions, however, occurred a conflict of interest, will warn the customer in advance of the nature and source of conflict of interest before acting it on a register which would record the incident.