Conflicts of Interest policy

Nucleus are committed to the highest standards of ethical conduct and integrity, conducting business in an honest and transparent way, without the use of corrupt practices or acts of bribery to obtain unfair advantage. 

The objective of this policy is to ensure that Nucleus meets its regulatory obligations, that customers can be confident in the commitment from Nucleus and the quality of its oversight and controls in managing the risks associated with Conflicts of Interests.

The objective of this Policy is to ensure that Nucleus:

  • meets its regulatory obligations
  • conducts its business with honesty and transparency in accordance with the best interests of its customers
  • identify and record all conflicts and potential conflicts of interest
  • manage any conflicts of interest such that our customers’ interests are not adversely affected and disclose these when required
  • will not offer, give, solicit or accept any inducement which is likely to conflict with any duties owed to customers.

This is delivered through our risk management framework by having appropriate policies, procedures, controls and oversight in place. There is appropriate accountability through the Senior Manager and Certification Regime, the three lines of defence (3LOD) and adequate governance structures. The Nucleus apportionment matrix documents sets out where accountability for decisions concerning Conflicts of Interest ultimately lies.