Conflicts of interest policy

Pioneer has taken all reasonable steps to identify the key conflicts (actual and potential) that it faces in its day-to-day business. Conflicts of interest can take different forms such as:

• Favouring one client over another
• Pioneer making a financial gain, or avoiding a financial loss, at the expense of the client
• A Pioneer member of staff being favoured over a client
• Pioneer providing to (or receiving from) a person other than the client, an inducement in relation to a service provided to the client, in the form of a financial interest
• Favouring Pioneer shareholders over a client.

Conflict management

Conflicts are unavoidable and Pioneer has established processes and procedures to ensure that all conflicts of interest that have been identified are managed as effectively as possible and in a manner that seeks to ensure that Pioneer acts in the best interests of its clients and/or potential clients. This will include, where applicable, disclosure of specific conflicts of interest to any and all relevant clients and/or potential clients.