Conflict of Interest Disclosure




Conflict of Interest Disclosure

Mulvihill is obligated to advise you of any circumstances that may create an actual or potential conflict between your economic interest and those of Mulvihill. The following is a list of potential conflicts that we have identified and steps we have taken to mitigate these:


  1. Mulvihill will receive compensation for administrative oversight and management of the fund. These have been fully disclosed to you and are in set out in the Offering Document. Please speak with your Mulvihill representative if you have not received a copy of this document.

  2. Mulvihill Premium Yield Fund is a related issuer to Mulvihill. Mulvihill has administrative oversight responsibility for the fund and may exercise discretion over the management of the fund’s portfolio.

  3. Staff of Mulvihill may have a beneficial ownership in units of the fund. Mulvihill has a personal trading policy that is designed to restrict these individuals from purchasing or redeeming units of the fund where they may be privy to information that has not been widely disclosed.

  4. Staff (and related persons) are also allowed to operate accounts at other registered firms. Mulvihill has adopted a personal trading policy that applies to all officers, directors and staff involved in investment management activities. These polices are designed to reasonably prevent staff from trading in advance of orders for the portfolios under management, or trading on the basis of their knowledge of the portfolios’ trading activities.

  5. Staff are allowed to participate in commercial and charitable activities outside Mulvihill. However, such activities, (including having a significant passive holdings of another operating business) are subject to management’s approval. Management will not approve any outside commercial or charitable activity if the staff person’s financial interests arising from such activity are in direct conflict with Mulvihill’s obligations to unit holders or the funds under management.

  6. Mulvihill has established policies and procedures regarding the receipt of gifts. Compliance staff must be notified of any gifts excess of a certain thresholds and will ask that the gift be returned or donated to charity if it is likely to create an actual or perceived conflict.

  7. Mulvihill requires all staff to notify the Chief Compliance Officer of any matters that may create an actual or perceived conflict of interest. Staff are also reminded of this obligation during annual compliance seminars.