Conflicts of Interest Policy


Equity Associates and your advisor are required to take reasonable steps to identify existing and reasonably foreseeable conflicts of interest between you the client and Equity Associates, and you the client and your advisor. Any identified conflicts of interest must be addressed in the best interests of you the client. Where a material conflict of interest cannot otherwise be addressed in your best interests, the conflict must be avoided. Your advisor is required to provide you with written disclosure of material conflicts of interest at account opening or in a timely manner thereafter.

Your advisor is required to provide Equity Associates with prompt reporting of all material conflicts of interest and refrain from any trading or advising activity in connection with a material conflict of interest unless: (i) the conflict has been addressed in the best interest of you the client, and (ii) your advisor has received consent from Equity Associates to proceed with the activity. If you feel that there may be a conflict of interest with Equity Associates and/or your advisor, please contact Equity Associates immediately for Equity Associates to review at