Conflicts of Interest Policy

Introduction

B.A. van Doorn is committed to serving its clients in a professional manner, in accordance with applicable laws and regulations. In line with Articles 4:11 and 4:88 of the Dutch Financial Supervision Act (Wft), and Article 35a of the Decree on Conduct of Business Supervision of Financial Enterprises (Bgfo), B.A. van Doorn must implement and maintain adequate organizational and administrative measures to prevent conflicts of interest or, if such conflicts arise, to identify and manage them.
A conflict of interest can occur between B.A. van Doorn and a client, between clients, or between a client and third parties involved in the service process.

This policy outlines how B.A. van Doorn identifies circumstances that may lead to conflicts of interest, which could potentially harm clients, and how internal measures and procedures are used to a) manage the risk of conflicts arising, and b) handle them appropriately if they do occur.

What is a conflict of interest?

A conflict of interest may arise in any area of B.A. van Doorn’s service delivery where either B.A. van Doorn or one of its clients gains a potential advantage at the expense of another client. Specific examples include conflicts arising from compensation structures, commissions, gifts, or market abuse.

Common types of conflicts may include:

• Conflicts between clients with opposing interests
• Conflicts between clients and B.A. van Doorn due to differing desired outcomes
• Conflicts between employees' personal interests and those of B.A. van Doorn or its clients
• Conflicts between B.A. van Doorn’s different business activities or entities within its group structure
• Conflicts between B.A. van Doorn and third parties (e.g. service providers) or between clients and these third parties

Preventing and managing conflicts of interest

The starting point is always to avoid conflicts of interest wherever possible. B.A. van Doorn is committed to placing the client’s interests first and remains constantly alert to any risk of conflict.

To prevent conflicts and manage actual or potential situations, B.A. van Doorn has established clear policies and procedures, documented in the B.A. van Doorn Manual. Key measures include:

• Client interests always come first for all employees.
• Policies exist to avoid mixing personal and professional interests, including regarding external positions and gifts.
• Strict procedures apply to personal investment transactions by employees, ensuring compliance and preventing insider trading or improper influence. These are overseen by the Compliance Officer.
• In all services, the client’s interest takes priority over B.A. van Doorn’s or related parties’ interests.

External Roles and Side Activities

Employees may engage in external roles that enhance the firm’s reputation and quality of service. However, these roles may also pose risks to independence and integrity. Therefore:
• Employees may not take on external positions without prior written approval from management.
• For unpaid side activities outside working hours, no approval is needed if:

• No work is performed for (potential) clients
• There is no direct connection to B.A. van Doorn’s business activities
• The company’s name or proprietary knowledge is not used

Gifts and Hospitality Policy

Employees may occasionally be offered gifts or favors in the course of their work. To ensure independence and integrity in all client relationships:
• Employees may not accept gifts or benefits that could even appear to influence their judgment.
• Invitations for lunches or dinners are acceptable if related to business.
• Invitations involving travel or entertainment must always be approved by management.
• Any gift or benefit over €100 must be reported to management.
• Cash gifts are strictly prohibited.

Giving gifts to external parties must also be approved by management.

Handling a Conflict of Interest

If a conflict of interest arises that affects a client, B.A. van Doorn will inform the client and discuss how to proceed. The firm may decide to decline or discontinue the requested service to protect the client's interests.

Periodic Review

B.A. van Doorn periodically reviews its products and services to identify any situations that may create actual or potential conflicts of interest. The effectiveness of the existing conflict management policy is also assessed. Changes will be made where necessary to protect clients' interests.

Conflict Management Procedure

If a conflict of interest does occur, the Compliance Officer will immediately notify the management. The affected client will be informed of the conflict and the approach B.A. van Doorn will take to resolve it. Clients may request additional information about the firm’s conflict of interest policies. In all cases, the client’s interest remains the top priority.