Conflicts of Interest Disclosure

Introduction

Brilliant Phoenix Capital Management Inc. ("the Firm") is committed to acting in the best interests of our clients. As a registered portfolio manager and investment fund manager (IFM) with the British Columbia Securities Commission, we recognize that conflicts of interest can arise in the course of our business. A conflict of interest occurs when the interests of the Firm or our employees may potentially interfere with the best interests of our clients. This document outlines the nature of potential conflicts of interest, the Firm’s role in identifying and managing these conflicts, and the steps we take to address them through avoidance, control, or disclosure.

Identifying and Managing Conflicts of Interest

The Firm takes a proactive approach in identifying potential conflicts of interest and has established robust procedures to manage them. Our primary objective is to ensure that conflicts are managed in a way that prioritizes our clients' interests. The Firm employs three main strategies for managing conflicts of interest: Avoidance, Control, and Disclosure.

Avoidance: Where possible, we avoid situations that could result in conflicts of interest.
Control: We implement policies and procedures to control conflicts and ensure that they do not adversely affect our clients' interests.
Disclosure: We disclose actual and potential conflicts to our clients to ensure transparency and informed decision-making.

Key Conflicts of Interest and Management Strategies

Below is a table that identifies key conflicts of interest that may arise in the management of our Limited Partnerships (LPs), and the strategies we employ to manage them.

  
    Conflict
    Management Strategy
    Steps Taken
  

    The Firm’s LP acquires ownership of related LPs managed by the Firm.
    Disclosure
    We disclose to clients any ownership interest the Firm has in related LPs to ensure transparency. Clients are informed of the potential conflict and the steps we take to mitigate any adverse effects.
  

    Fees and incentives may be structured to benefit the Firm rather than clients.
    Control
    The Firm has implemented a clear fee structure and incentive policies that are aligned with industry standards and designed to prioritize client interests. Regular audits and reviews are conducted to ensure compliance.
  

    Personal trading by employees that could conflict with client interests.
    Avoidance
    Employees are required to pre-clear personal trades and adhere to a personal trading policy that prohibits trading on material non-public information and conflicts with client trades.
  

    Allocation of investment opportunities between client accounts and the Firm’s accounts.
    Control
    We have established fair allocation policies and procedures to ensure that investment opportunities are distributed equitably among client accounts. Periodic reviews and audits are conducted to monitor adherence to these policies.
  

    Preferential treatment of certain clients over others.
    Disclosure
    We disclose our allocation policies and any preferential treatment arrangements to clients. This ensures transparency and allows clients to make informed decisions about their investments.
  

Conclusion

At Brilliant Phoenix Capital Management Inc., we are dedicated to managing conflicts of interest effectively to protect our clients’ best interests. By employing strategies of avoidance, control, and disclosure, we strive to maintain transparency and trust with our clients. Should you have any questions or require further information, please do not hesitate to contact us.