Conflict of Interest Policy

Last updated: March 4, 2025

1. Purpose and Scope

PALANTEX is committed to maintaining the highest standards of integrity, transparency, and professionalism. This Conflict of Interest Policy is designed to identify, prevent, disclose, and manage any actual, potential, or perceived conflicts of interest that may arise in the course of PALANTEX’s business activities.

This policy applies to all employees, officers, directors, contractors, affiliates, and representatives of PALANTEX.

2. Definition of a Conflict of Interest

A conflict of interest arises when personal, professional, financial, or other interests interfere, or appear to interfere, with the duty to act in the best interests of clients and PALANTEX.

Conflicts may be actual, potential, or perceived and may arise in various situations, including but not limited to financial interests, personal relationships, outside business activities, or the receipt of gifts or incentives.

3. General Principles

All persons subject to this policy must:

Act honestly, fairly, and professionally at all times
Place clients’ interests above personal or corporate interests
Avoid situations that could give rise to conflicts of interest
Disclose promptly any conflict of interest when identified

4. Identification and Disclosure

Employees and representatives are required to identify and disclose any situation that could reasonably be considered a conflict of interest. Disclosures must be made as soon as the conflict is identified and include sufficient detail to allow proper assessment.

PALANTEX maintains internal procedures to record and assess disclosed conflicts.

5. Management of Conflicts

Where a conflict of interest is identified, PALANTEX will take appropriate steps to manage it in a fair and transparent manner. These measures may include:

Implementing information barriers or segregation of duties
Restricting or monitoring certain activities
Requiring divestment or withdrawal from conflicting roles
Providing clear disclosures to affected clients
Declining to act where the conflict cannot be adequately managed

6. Gifts, Benefits, and Incentives

Employees and representatives must not offer, give, solicit, or accept gifts, benefits, or incentives that could impair, or appear to impair, their objectivity or independence. Any permissible gifts or benefits must comply with internal thresholds and disclosure requirements.

7. Personal Transactions

Personal trading or investment activities must not conflict with clients’ interests or PALANTEX’s obligations. PALANTEX may impose restrictions, reporting obligations, or pre-approval requirements on personal transactions where appropriate.

8. Monitoring and Review

PALANTEX regularly monitors conflicts of interest and reviews this policy to ensure its effectiveness and ongoing compliance with applicable laws and regulations.

9. Breaches of Policy

Failure to comply with this policy may result in disciplinary action, up to and including termination of employment or contractual relationships, and may involve regulatory or legal consequences where applicable.

10. Contact

If you have any questions or wish to disclose a conflict of interest, please contact:

PALANTEX – Complaints Department
complaints@palantex.com

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