HSBC Global Asset Management (USA) Inc.
Terms and conditions
Confirmation of Institutional Investor Status:
If you are entering the Website for Institutional Investors, you hereby represent and warrant that you are any one of the following:
(A) person described in FINRA Rule 4512(c), regardless of whether the person has an account with a member; (B) governmental entity or subdivision thereof; (C) employee benefit plan, or multiple employee benefit plans offered to employees of the same employer, that meet the requirements of Section 403(b) or Section 457 of the Internal Revenue Code and in the aggregate have at least 100 participants, but does not include any participant of such plans; (D) qualified plan, as defined in Section 3(a)(12)(C) of the Exchange Act, or multiple qualified plans offered to employees of the same employer, that in the aggregate have at least 100 participants, but does not include any participant of such plans; (E) member or registered person of such a member; and (F) person acting solely on behalf of any such institutional investor.
“Institutional Investor” does not include “Retail Customer” as defined in Regulation Best Interest under the Securities Exchange Act of 1934.
GENERAL TERMS AND CONDITIONS APPLICABLE TO ALL USERS:
This website ("Website") is currently intended for U.S. residents who access it from within the United States. Because of this we cannot guarantee that the Website, or the information therein, complies with the local laws or regulations of, or is appropriate for use in, any other jurisdiction from which you access it. If you choose to access this Website from a jurisdiction other than the United States, you do so at your own risk and HSBC Asset Management (which for the purpose of these Terms includes HSBC Global Asset Management (USA) Inc.) will not be liable for any breach of local law or regulation that you commit as a result of doing so. It is your responsibility to be aware of and to observe all applicable laws and regulations of any relevant jurisdiction.
You are wholly responsible for use of this Website by any person using your computer and you must ensure that any such person complies with these Terms and Conditions.
The information provided on this Website is not intended for distribution to, or use by, any person in any jurisdiction where such distribution or use would be contrary to law or regulation. Please note that there are restrictions imposed by law on the distribution of this information and the countries in which our funds are authorized for sale.
By confirming that you have read this important information, you also (i) agree that all access to this Website by you will be subject to the disclaimer, risk warnings and other information set out herein.
This Website or information contained or incorporated by reference has not been, and will not be submitted to, become approved/verified by, or registered with, any relevant government authorities under the local laws. This Website is not intended for and should not be accessed by persons located or resident outside of the United States. It is your responsibility to be aware of, to obtain all relevant regulatory approvals, licenses, verifications and/or registrations under, and to observe all applicable laws and regulations of any relevant jurisdiction in connection with your use of this Website.
Unless otherwise expressly stated, neither the information, nor any opinion contained in the Website constitutes an offer to sell or solicitation or an offer to buy any securities or financial instruments or any other products, accounts or services or any advice or recommendation with respect to such securities, financial instruments or other products, accounts or services. You are advised to obtain appropriate legal, accounting and tax advice where necessary. The material contained on this Website is for information only and does not constitute investment or other financial advice or a recommendation to buy or sell investments. Securities or financial instruments discussed in this Website may not be suitable for all investors. The information provided is for solely for informational purposes. If you are unsure about the meaning of any information provided, please consult your financial or other professional adviser. You should determine whether a particular service or product is suitable for your investment needs or should seek professional advice.
Please refer to offering documents for further information concerning specific products.
HSBC Funds may be made available by HSBC Securities (USA) Inc., member FINRA / NYSE / SIPC. Affiliates of HSBC Asset Management (including HSBC Securities (USA) Inc.) receive fees for providing various services to the HSBC Funds.
HSBC Funds are distributed by Foreside Distributors, L.P., Inc., member FINRA.
Call a Registered Representative at 888-936-4722 for an HSBC Fund prospectus. Investors should consider the investment objectives, risks, charges and expenses of the mutual fund carefully before investing. The prospectus contains this and other information about the mutual fund. Read the prospectus carefully before investing.
HSBC Asset Management and its affiliates do not provide tax advice. Please consult your tax advisor for personalized assistance.
NOT FDIC INSURED | NO BANK GUARANTEE | MAY LOSE VALUE
Please note that the value of investments and the income derived from them may fluctuate and an investor may not receive back the amount originally invested. Past performance should not be seen as an indication of future performance and the value and any income arising from any investment referred to on this Website may go down as well as up. In particular, you may not get back the full amount invested. Investments are not deposits or obligations of, or guaranteed or endorsed by, any bank (including HSBC Bank (USA), N. A.), and are not federally insured or guaranteed by the U.S. government, the FDIC, the Federal Reserve Board or any other agency. Where an investment is denominated in a currency other than US dollars, exchange rates may have an adverse effect on the value price or income of that investment. In the case of investments for which there is not a recognized market it may be difficult for investors to sell their investment or to obtain reliable information about its value or the extent of the risks to which it is exposed. The information contained in this website may be affected by changes to laws or regulations and is subject to alteration without notice. Changes in current rates of exchange or taxation may have an effect on the value price or income of investments. Current tax levels and relief may change and the value of any relief depends on individual circumstances. Any forecast, projection or target is indicative only and is not guaranteed in any way. HSBC Group accepts no liability for any failure to meet such forecast, projection or target. Some of the investments and services on this site may not be available in or appropriate for a retirement savings plan. Please contact your financial adviser about any investment restrictions associated with your particular plan.
POTENTIAL CONFLICTS OF INTERESTS
A company or person connected or associated with the HSBC Group may be an underwriter or distributor of, or a market maker or otherwise hold positions in, a security or financial instrument (or in options, futures or other derivative instruments thereon) which has been discussed in this Website and may receive fees for providing services to the issuers of such securities. Members of HSBC Group may also act as advisor or lender or other service provider to an issuer or participate on a creditors' committee relating to the restructuring of an issuer mentioned herein. In addition, employees of HSBC Group may have positions or effect transactions in securities or financial instruments mentioned herein (or options with respect thereto) or serve as directors of issuers mentioned herein.
COPYRIGHT AND OTHER INTELLECTUAL PROPERTY
HSBC Asset Management, or other members of HSBC Group (collectively "Affiliates") maintain this Website and certain other websites that are linked to this site, and is the owner or the authorized user of this Website and certain other websites linked to the Website, as well as all text, images, graphics, photos, animation, music, sounds and other materials contained within these websites.
The materials contained within these websites, including, without limitation, any copyrights, trademarks, service marks, and all other proprietary materials, are protected by the U.S. and international copyright laws and treaty provisions, trademark laws, and other proprietary rights laws. HSBC Asset Management and/or its Affiliates also own(s) a copyright in the selection, coordination and arrangement of the material contained within these Websites. The material contained within these websites is provided by HSBC Asset Management and/or its Affiliates only for lawful uses by customers, employees, and members of the general public. The material may not be copied, republished, incorporated into another website or reproduced (whether by linking, framing, or any other method), transmitted, distributed, uploaded, posted, used to create a derivative work or exploited in any other way without the express written consent of HSBC Asset Management. You do not acquire any ownership rights in the content contained in this website as a result of accessing it or using it.
Nothing contained on this Website should be considered as granting, by implication, estoppel or otherwise, any license or right to use any trade-marks, logos, or other names, including but not limited to, those identifying HSBC Asset Management, any Affiliate and their respective licensors, suppliers or contractors, or their respective products and services displayed on this Website, without the expressed written consent of the applicable rights holder.
All content is made available on this Website solely for your own personal uses or for your own internal, ordinary, lawful, business information uses. You are not granted any rights for sale, resale, licensing, sub-licensing or promotional use with respect to the content. You agree to abide by all copyright notices, information and restrictions contained in or displayed with any content. Except with the prior written consent of HSBC Asset Management, you may not reproduce, store, transmit, publish, broadcast, distribute or make available any content. You may not, without the permission of HSBC Asset Management or the respective owner(s), modify the content, or remove or alter any copyright and other proprietary notices contained in the content. HSBC Asset Management reserves the right to change any and all content contained on this Website at any time without notice. All rights in or to content that are not expressly granted in these Terms are reserved by HSBC Asset Management or the other owner(s) of content.
NO RELIANCE ON DATA
Reasonable precautions have been taken to ensure that the information contained in this Website, including but not limited to account information and pricing data, are complete and accurate. However, due to the nature of information delivery technology and the necessity of using multiple data sources, including third party information, HSBC Asset Management is unable to assure the accuracy of the data you access through this Website. Information presented herein is only as of the date published or indicated and may be superseded by subsequent market events or other reasons. None of HSBC Group nor its affiliates have any duty to update this Website or the information contained herein. HSBC GROUP (INCLUDING HSBC ASSET MANAGEMENT) SHALL NOT BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY DAMAGES ARISING FROM ANY ACTIONS OR INVESTMENT DECISIONS TAKEN BY YOU BASED ON THE ACCURACY OF THE DATA PRESENTED THROUGH THIS WEBSITE. NOTHING HEREIN SHALL IN ANY WAY CONSTITUTE A WAIVER OR LIMITATION OF ANY RIGHTS WHICH YOU MAY HAVE UNDER ANY US FEDERAL OR STATE SECURITIES LAW.
CAUTIONS ABOUT FUTURE OR "FORWARD-LOOKING" STATEMENTS
Speculation or stated beliefs about future events, such as market and economic conditions, company or security performance, upcoming product offerings or other projections are "forward-looking statements" within the meaning of the Private Securities Litigation Reform Act of 1995 and involve risks and uncertainties. General business, market, economic and political conditions could cause actual results to differ materially from what we presently anticipate or project.
NONE OF HSBC ASSET MANAGEMENT OR ANY MEMBER OF HSBC GROUP WILL BE LIABLE OR HAVE ANY RESPONSIBILITY OF ANY KIND FOR ANY LOSS OR DAMAGE THAT YOU INCUR ARISING FROM OR IN CONNECTION WITH ANY ACT OR OMISSION OF HSBC ASSET MANAGEMENT OR OTHER MEMBER OF THE HSBC GROUP IN MAKING THIS WEBSITE AVAILABLE TO YOU OR ANY OTHER CAUSE RELATING TO YOUR ACCESS TO OR USE OF THIS WEBSITE, WHETHER OR NOT THE CIRCUMSTANCES GIVING RISE TO SUCH CAUSE MAY HAVE BEEN WITHIN THE CONTROL OF ANY MEMBER OF THE HSBC GROUP OR WITHIN THE CONTROL OF ANY VENDOR PROVIDING SOFTWARE OR SERVICES SUPPORT FOR THIS WEBSITE.
WITHOUT LIMITING THE FOREGOING, NEITHER HSBC ASSET MANAGEMENT, ITS PARENT, AFFILIATES OR SUBSIDIARIES, OR ANY OTHER PARTY INVOLVED IN THE CREATION, PRODUCTION OR DELIVERY OF THE INFORMATION AT THIS WEBSITE, NOR THE OFFICERS, DIRECTORS, EMPLOYEES OR REPRESENTATIVES OF ANY OF THE FOREGOING, ARE LIABLE IN ANY WAY FOR ANY DIRECT, SPECIAL, PUNITIVE, CONSEQUENTIAL, OR INDIRECT DAMAGES (INCLUDING WITHOUT LIMITATION LOST PROFITS, COST OF PROCURING SUBSTITUTE SERVICE OR LOST OPPORTUNITY) ARISING OUT OF OR IN CONNECTION WITH THIS WEBSITE OR THE USE OF THIS WEBSITE OR A LINKED WEBSITE OR WITH THE DELAY OR INABILITY TO USE THIS WEBSITE OR A LINKED WEBSITE, WHETHER OR NOT HSBC ASSET MANAGEMENT (OR ANY OTHER MEMBER OF HSBC GROUP) IS MADE AWARE OF THE POSSIBILITY OF SUCH DAMAGES. THIS LIMITATION INCLUDES, BUT IS NOT LIMITED TO, THE TRANSMISSION OF ANY VIRUSES, DATA OR HARMFUL CODE THAT MAY AFFECT A USER'S EQUIPMENT, ANY INCOMPATIBILITY BETWEEN THIS WEBSITE'S FILES AND THE USER'S BROWSER OR OTHER WEBSITE ACCESSING PROGRAM, FAILURE OF ANY ELECTRONIC OR TELEPHONE EQUIPMENT, COMMUNICATION OR CONNECTION LINES, UNAUTHORIZED ACCESS, THEFT, OPERATOR ERRORS, OR ANY FORCE MAJEURE EVENT. HSBC ASSET MANAGEMENT DOES NOT GUARANTEE CONTINUOUS, UNINTERRUPTED OR SECURE ACCESS TO THIS WEBSITE OR A LINKED WEBSITE. THE CONTENT, ACCURACY, OPINIONS EXPRESSED, AND OTHER LINKS PROVIDED BY THE LINKED WEBSITES ARE NOT INVESTIGATED, VERIFIED, MONITORED OR ENDORSED BY HSBC ASSET MANAGEMENT. THE INFORMATION, SOFTWARE, PRODUCTS AND DESCRIPTION OF SERVICES PUBLISHED ON THE WEBSITE (INCLUDING INFORMATION PROVIDED BY THIRD PARTIES) OR A LINKED WEBSITE MAY INCLUDE INACCURACIES OR TYPOGRAPHICAL ERRORS, AND HSBC ASSET MANAGEMENT AND/OR ITS AFFILIATES SPECIFICALLY DISCLAIMS ANY LIABILITY FOR SUCH INACCURACIES OR ERRORS. CHANGES ARE PERIODICALLY MADE TO THE INFORMATION ON THE WEBSITE AND LINKED WEBSITES. HSBC ASSET MANAGEMENT MAY MAKE IMPROVEMENTS OR CHANGES TO THE WEBSITE AT ANY TIME. SOME STATES DO NOT ALLOW THE LIMITATION OF LIABILITY OR EXCLUSION OF WARRANTIES, SO THE ABOVE LIMITATIONS AND EXCLUSIONS MAY NOT APPLY TO YOU. IN THOSE STATES, HSBC's LIABILITY WILL BE LIMITED TO THE GREATEST EXTENT PERMITTED BY LAW. IN NO EVENT, OTHER THAN AS PROVIDED FOR BY APPLICABLE LAW, SHALL HSBC GROUP’S AGGREGATE LIABILITY ARISING FROM OR RELATED TO YOUR ACCESS TO OR USE OF THIS WEBSITE EXCEED ONE THOUSAND DOLLARS ($1000).
NOTHING HEREIN SHALL IN ANY WAY CONSTITUTE A WAIVER OR LIMITATION OF ANY RIGHTS WHICH YOU MAY HAVE UNDER ANY US FEDERAL OR STATE SECURITIES LAW.
ALL PRODUCTS, SERVICES AND CONTENT ON THIS WEBSITE ARE PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, SECURITY, ACCURACY, COMPLETENESS OR REASONABLENESS OR THAT IT IS FIT FOR YOUR PARTICULAR PURPOSE, AND IT SHOULD NOT BE RELIED ON AS SUCH. NEITHER HSBC ASSET MANAGEMENT NOR ITS PARENT, AFFILIATES OR SUBSIDIARIES ENDORSES ARE RESPONSIBLE FOR THE ACCURACY OR RELIABILITY OF ANY INFORMATION ON THIS WEBSITE. IT IS THE RESPONSIBILITY OF THE USER TO EVALUATE THE ACCURACY, RELIABILITY, TIMELINESS AND COMPLETENESS OF ANY INFORMATION AVAILABLE ON THIS WEBSITE. HSBC GROUP (INCLUDING HSBC ASSET MANAGEMENT) SPECIFICALLY DISCLAIMS ANY DUTY TO UPDATE THE INFORMATION ON THE WEBSITE.
USER AGREES TO INDEMNIFY, DEFEND, AND HOLD HARMLESS HSBC ASSET MANAGEMENT, ITS PARENT, AFFILIATES OR SUBSIDIARIES, AND ANY OTHER PARTY INVOLVED IN THE CREATION, PRODUCTION OR DELIVERY OF THIS WEBSITE, AS WELL AS THE OFFICERS, DIRECTORS, EMPLOYEES OR REPRESENTATIVES OF ANY OF THE FOREGOING FROM ANY LIABILITY, LOSS, CLAIM AND EXPENSE, INCLUDING ATTORNEY'S FEES RELATED TO A USER'S VIOLATION OF THESE TERMS AND CONDITIONS OR THE USE OF THE SERVICES AND INFORMATION PROVIDED AT THIS WEBSITE.
NOTHING HEREIN SHALL IN ANY WAY CONSTITUTE A WAIVER OR LIMITATION OF ANY RIGHTS WHICH YOU MAY HAVE UNDER ANY US FEDERAL OR STATE SECURITIES LAW.
You represent and warrant to HSBC Asset Management that you will not use this Website for any purpose that is unlawful or prohibited by these Terms and Conditions, including but not limited to attempting or actually (a) disrupting, impairing or otherwise interfering with the operation or integrity of the Website or circumventing any Website security system; (b) collecting any information about other users of the Website; or (c) systematically extracting content or other information or data contained in the Website to populate databases or other websites.
Clicking on certain links within this Website or certain other websites that are linked to this Website may take you to other websites, or may display information on your computer screen from other websites, which are not maintained by HSBC Asset Management and/or its Affiliates. Such websites may contain terms and conditions, privacy provisions, confidentiality provisions, or other provisions that differ from the terms and conditions applicable to this website. Links to other Internet services and websites are provided solely for the convenience of users. A link to any service or website is not an endorsement of any kind of the service or website, its content, or its sponsoring organization.
HSBC ASSET MANAGEMENT AND ITS PARENTS, AFFILIATES, AND SUBSIDIARIES ASSUME NO RESPONSIBILITY OR LIABILITY WHATSOEVER FOR THE CONTENT, ACCURACY, RELIABILITY OR OPINIONS EXPRESSED IN A WEBSITE, TO WHICH THIS WEBSITE IS LINKED (A "LINKED SITE") AND SUCH LINKED SITES ARE NOT MONITORED, INVESTIGATED, OR CHECKED FOR ACCURACY OR COMPLETENESS BY HSBC ASSET MANAGEMENT AND/OR ITS AFFILIATES. IT IS THE RESPONSIBILITY OF THE USER TO EVALUATE THE ACCURACY, RELIABILITY, TIMELINESS AND COMPLETENESS OF ANY INFORMATION AVAILABLE ON A LINKED SITE. ALL PRODUCTS, SERVICES AND CONTENT OBTAINED FROM A LINKED SITE ARE PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, SECURITY, OR ACCURACY.
PASSWORDS / PINS
If you maintain an account that you access through this Website, you are solely responsible for maintaining the confidentiality of your account and password (or Personal Identification Number or PIN) and for restricting access to your computer. You agree to accept responsibility for all activities occurring under your account or password. Notify us immediately if you become aware of any disclosure, loss, theft or unauthorized use of your password.
HSBC Asset Management does not knowingly market to, or solicit, or collect personal information from children under age 18.
CHOICE OF LAW
All website activity or use and these Terms and Conditions are governed by the laws of the United States of America and the laws of the State of New York, without regard to conflict of law principles.
WEBSITE CONTENT AND MATERIAL
The information and materials contained in this website, including but not limited to these Terms and Conditions and any product information, are subject to change without notice. Users are deemed to be apprised of and bound by any such changes. Not all products and services are available in all geographic areas. Your eligibility for particular products and services is subject to final determination and acceptance by HSBC Asset Management.
WAIVER AND SEVERABILITY
Any waiver of any provision contained in these Terms and Conditions shall not be deemed to be a waiver of any other right, term or provision of these Terms and Conditions. If any provision in these Terms and Conditions shall be or become wholly or partially invalid, illegal or unenforceable, such provision shall be enforced to the extent it is legal and valid and the validity, legality and enforceability of the remaining provisions shall in no way be affected or impaired thereby.
ACCESS TO SECURED AREAS
Access to and use of password protected and/or secure areas of this website is restricted to authorized users only. Unauthorized persons attempting to access these areas of the website may be subject to prosecution.
These Terms and Conditions were last updated on May 17, 2022. Please check periodically for changes.
For our Online Privacy Statement, please refer to the following link: Online Privacy Statement - HSBC Bank USA
For our Accessibility Policy, please refer to the following link: Accessibility & Disability Accommodation - HSBC Bank USA
HSBC GLOBAL ASSET MANAGEMENT CONFLICTS OF INTEREST POLICY SUMMARY
HSBC Global Asset Management We are HSBC Global Asset Management, the asset management division of the HSBC Group. We develop and manage investment management products and services for clients around the world, from individual retail customers to major multinational corporate clients, sovereign wealth funds and financial institutions clients.
Conflicts of Interest
A Conflict of Interest (“Conflict”) is a situation or arrangement where HSBC Asset Management (AM), or a company with which it has an association, (“AM”) and/or any of its employees is subject to multiple influences, the competition of which might adversely affect decision-making or outcomes in the course of conducting business.
Conflicts of interest can potentially exist between AM and its clients where AM is incentivized to favor itself in its decisions rather than the client. Conflicts also exist between two or more sets of clients, or funds, by virtue of the fact AM is responsible for managing their assets across different investment strategies.
Because it provides a wide range of services, AM may from time to time have interests that conflict with its clients’ interests or with duties that it owes to its clients.
Conflicts can arise between:
- One client and another;
- AM and a client;
- An employee and a client;
- An employee and AM-; and/or
- One part of HSBC Group and AM.
AM has established procedures that are designed to identify, and prevent or manage Conflicts. These include arrangements to safeguard the interests of clients.
How AM deals with Conflicts
AM’s organizational structures are designed so that behavior that could lead to Conflicts is not incentivized or rewarded.
Where necessary, AM restricts the flow of information to certain employees in order to protect its clients’ interests.
AM has procedures in place to:
- Identify all types of potential Conflicts that could reasonably arise in the context of its activities;
- Maintain registers of all potential Conflicts identifies;
- Prevent or manage Conflicts on an ongoing basis;
- Disclose Conflicts where appropriate; and
- Maintain evidence of all occurrences of Conflicts that cannot be managed.
Members of HSBC Group (including AM) are required to consider the types of potential Conflict relevant to the specific services and activities they carry out.
For example, potential Conflicts are considered when;
- Developing a new product;
- Establishing or amending any cross-referral, revenue sharing or joint venture arrangements; or
- Transferring businesses, activities or operations (or parts thereof) to another part of HSBC Group.
When potential Conflicts involve clients, the assessment also takes into account whether the Group and/or any employee:
- Is likely to make a financial gain or avoid a financial loss at the expense of any client;
- Has an interest in the outcome of a service provided to a client, or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
- Has a financial, or other incentive to favor the interest of one client (or group of clients) over another; and/or
- Receives or will receive an inducement in relation to a service provided to the client from a person other than the client.
AM maintains internal registers, documenting and evaluating all identified potential Conflicts. These registers also record the mitigating controls in place to manage each type of Conflict.
Preventing or managing Conflicts
AM structures the remuneration, deployment and management of employees in a way that minimizes Conflicts.
Conflicts clearing procedures ensure that Conflicts are escalated and managed before AM is committed to a transaction.
In some cases, AM will consider declining to act for one of more clients. For example, if:
- A Conflict is too great;
- Confidentiality obligations prevent adequate disclosure (see Disclosure, below); and/or
- Informed consent cannot be obtained, or is an insufficient control to manage a Conflict.
A dedicated Conflicts Management Office, reporting to the Regulatory Compliance department, is the point of escalation for significant Conflicts, and resolution of cross-business Conflicts brought to its attention. Written reports on the services and activities reflected in the Registers of Conflicts are presented to senior management of the Group at least annually.
Where AM has used all reasonable efforts to manage a Conflict, but the risk of damage to a client, or third party’s interest remains, a specific disclosure to the third party about the presence of a Conflict will be made.
Disclosures will be made prior to the conclusion of a contract, in a durable medium, and include sufficient detail, taking into account the nature of the client, to enable that client to taken an informed decision.
AM requires its employees to apply good judgement and act with integrity, taking all appropriate steps to:
- Avoid personal Conflicts (for example, in their personal account dealings); and
- Proactively escalate personal Conflicts that do arise.
No employee is permitted to advise a Client on any matter in which they have a personal interest, nor take commercial decisions on behalf of the HSBC Group if those decisions are connected to their personal or external business affairs until steps have been taken to satisfactorily manage the Conflict.
AM will take all reasonable steps to identify, and prevent or manage, the Conflicts of Interest.