Conflict Of Interest Policy

Envalis operates as an independent analytical entity whose models and analyses are prepared in an objective, transparent manner that is resistant to the influence of the commercial interests of third parties. The management of conflicts of interest is an integral part of the risk management system and of the modelling process, and comprises the identification, assessment and monitoring of potential conflicts at every stage of a project.

A conflict of interest means a situation in which the interests of Envalis, its employees or affiliated entities may affect, or appear to affect, the independence, objectivity or integrity of the services provided. Conflicts may be actual, potential or perceived by third parties.

Each project is subject to a conflict of interest assessment before it begins. The assessment covers in particular the fee structure, business relationships with project participants, the potential provision of services to more than one party to a transaction, and any personal connections of members of the project team.

Where a conflict of interest is identified, Envalis applies appropriate remedial measures, including restricting access to information, separating project teams, disclosing the conflict to the client, or changing the structure in which the project is carried out. In situations where a conflict cannot be effectively mitigated, Envalis declines to accept or to continue the engagement.

The modelling process is a key element in mitigating conflicts of interest. The models are based on market data, documented sources and standard analytical scenarios. Adjusting the assumptions or results of the models in order to achieve a particular financial outcome is not permitted.

In order to ensure the independence of its analyses, Envalis separates the functions of model construction and model validation. Each model is subject to independent verification covering its mathematical consistency, the realism of its assumptions and its impact on key economic indicators.

The remuneration of Envalis is, as a rule, independent of the results of projects or models. Where an element of remuneration is linked to the outcome of a transaction, this fact is disclosed.

Envalis applies organisational and technical measures that limit the flow of information between projects and ensure the confidentiality of data. All conflicts of interest are documented and subject to ongoing monitoring.