Effective Date: 2018
Baer Invest and Capital Management DOO (“Company”, “we”, “us”, or “our”) is committed to conducting its business with integrity, transparency, and fairness.
This Conflict-of-Interest Policy outlines how the Company identifies, manages, and mitigates potential conflicts of interest in its advisory and investment-related activities.
- Purpose
The purpose of this Policy is to:
- Identify situations where conflicts of interest may arise
• Establish procedures to prevent or manage such conflicts
• Ensure fair treatment of clients and counterparties
• Protect the integrity and reputation of the Company
- Definition of Conflict of Interest
A conflict of interest arises when the Company, its owner, or associated persons have personal, financial, or professional interests that could improperly influence business decisions or client outcomes.
Conflicts may be actual, potential, or perceived.
- Situations Where Conflicts May Arise
Conflicts of interest may arise in circumstances including, but not limited to:
- Advising multiple clients with competing interests
• Receiving compensation from third parties
• Personal financial interests in a transaction
• Business relationships with counterparties involved in a client engagement
• Referral arrangements or strategic partnerships
• Ownership stakes in projects being advised upon
- Identification and Assessment
The Company evaluates potential conflicts during:
- Client onboarding
• Engagement structuring
• Transaction negotiations
• Introduction of third-party partners
Potential conflicts are assessed based on materiality and risk to fairness.
- Management and Mitigation Measures
Where a conflict is identified, the Company may implement one or more of the following measures:
- Full disclosure to affected parties
• Obtaining informed written consent
• Segregation of advisory roles
• Limiting access to sensitive information
• Declining or terminating the engagement
If a conflict cannot be effectively managed, the Company will refuse or withdraw from the transaction.
- Transparency and Disclosure
Where appropriate, conflicts will be disclosed clearly and in writing before proceeding with an engagement.
Clients will be given sufficient information to make informed decisions.
- Independent Judgment
The Company commits to exercising independent professional judgment in all advisory activities.
Business decisions are made based on objective assessment and the best interests of the engagement, not personal gain.
- Personal Transactions
The owner and associated persons shall avoid personal investments or business activities that materially conflict with active client engagements.
Where unavoidable, full disclosure procedures apply.
- Record Keeping
The Company maintains records of identified conflicts and the actions taken to manage or resolve them.
- Review and Updates
This Policy is reviewed periodically to ensure ongoing effectiveness and compliance with applicable legal and ethical standards.