Controls designed to protect the mandate.
Ownership alignment does not remove conflict. Contim names the conflicts created by its own investment book and applies a framework for custody, cash, valuation, allocation and trade sequencing.
Alignment and conflict can exist together.
Contim holding its own positions is an advantage because our capital is exposed to the same investment judgement as client portfolios. It is also a potential conflict, and acknowledging that conflict is the beginning of managing it.
Governance is therefore built around clear asset ownership, segregation of money, defined authority, independent evidence and a written allocation approach when an opportunity could suit both Contim and a client mandate.
Clear separation. Clear authority. Clear evidence.
The company profile sets out the following framework for protecting client mandates and documenting how decisions are made.
| Control | How the framework operates |
|---|---|
| Assets in client name | Securities are held with an independent custodian in the client's name or a designated client account, rather than becoming Contim balance-sheet assets. |
| Segregated client money | Cash is maintained separately from the firm's own funds and reconciled on the cycle established for the engagement. |
| No unilateral withdrawal | Trading authority does not create authority to move client money to a third party without the required client instruction. |
| Independent valuation | Property valuations are obtained from an independent qualified valuer on the cycle agreed for the mandate. |
| Review & audit trail | Reconciliations, approvals, transactions and relevant supporting records are retained for client review and formal assurance processes. |
| Allocation policy | Where an opportunity suits both Contim and a client, the written policy gives the client mandate priority. |
| Trade sequencing | Client orders are executed before the firm's own order in the same security, with records retained for review. |
Decide the rule before the opportunity.
Three situations deserve explicit treatment because they can put Contim's proprietary interests beside those of a client.
Limited opportunity
When both books qualify, client mandates are allocated first. Contim receives what remains, if anything.
Sale from our book
No sale from Contim into a client account without independent valuation and the client's written consent.
Shared holding
A Contim position is disclosed before a client decides, including the relevant size and date information.
Material decisions require a record.
Investment committee review creates an evidence trail for material allocations and acquisitions across both the firm's own book and client mandates. The record should show the information considered, decision reached and any conflict identified.
Identify
Surface investment, liquidity, legal and conflict risks before approval.
Challenge
Test assumptions, downside scenarios and the reason capital should be committed.
Approve
Apply the authorities, limits and conditions documented for the decision.
Minute
Retain a clear record that can be reviewed during reporting and oversight.