CONFLICTS OF INTEREST POLICY
Last Updated: December 2025
- Introduction
Karl Finance LLP (“Karl Finance“, “we“, “us“, or “our“) is committed to identifying, managing, and where appropriate disclosing conflicts of interest that may arise in connection with The Amplitude Fund.
This policy sets out how we, together with our regulatory partner Falcon Investment Management Ltd (“Falcon“), manage conflicts of interest to ensure fair treatment of all investors.
- Regulatory Context
The Amplitude Fund (Falcon Hybrid SPC – The Amplitude Fund SP) is managed by Falcon Investment Management Ltd, which is authorised and regulated by the Financial Conduct Authority (FCA) as a Full Scope Alternative Investment Fund Manager (FRN: 673552).
Falcon is required under the FCA’s SYSC rules and the Alternative Investment Fund Managers Directive (AIFMD) to:
- Maintain and operate effective organisational and administrative arrangements to identify, prevent, manage, and monitor conflicts of interest
- Maintain a conflicts of interest policy appropriate to the size and nature of its business
- Disclose conflicts that cannot be adequately managed
Karl Finance, as Sponsor and Investment Advisor to the Fund, operates under Falcon’s regulatory umbrella and adheres to the same standards.
- What Is a Conflict of Interest?
A conflict of interest arises when:
- The interests of Karl Finance, Falcon, or their personnel conflict with the interests of the Fund or its investors
- The interests of one investor conflict with those of another investor
- A duty owed to one party conflicts with a duty owed to another
Conflicts may be actual, potential, or perceived.
- Types of Conflicts We Have Identified
The following are examples of conflicts that may arise in connection with the Fund:
Conflict Type | Description |
Fee arrangements | Karl Finance receives performance and management fees, which could incentivise excessive risk-taking |
Allocation of trades | Where multiple portfolios are managed, ensuring fair allocation of investment opportunities |
Proprietary interests | Karl Finance owns VISOR (patent pending) and licences Wraithbot; decisions about their use could favour Karl Finance’s commercial interests |
Related party transactions | Any transactions between the Fund and Karl Finance, Falcon, or their affiliates |
Personal account dealing | Staff may hold personal investments that could conflict with Fund positions |
Gifts and inducements | Receipt of benefits from brokers, service providers, or counterparties |
Outside business interests | Staff involvement in other business activities that could compete or conflict |
- How We Manage Conflicts
We employ the following measures to manage conflicts of interest:
Governance and Oversight
- Falcon, as the independent AIFM, provides oversight of all investment management activities
- Clear segregation of duties between portfolio management, risk management, and compliance functions
Policies and Procedures
- Personal account dealing policy requiring pre-clearance and reporting of staff trades
- Gifts and inducements policy with monetary thresholds and approval requirements
- Best execution policy ensuring trades are executed in the best interests of the Fund
- Fair allocation policy for investment opportunities across portfolios
Disclosure
- Material conflicts that cannot be adequately managed are disclosed to investors
- Related party transactions are disclosed in the Fund’s financial statements
Remuneration
- Fee structures are clearly disclosed in the Fund’s offering documents
- Performance fees are subject to a high-water mark to align interests with investors
Training and Awareness
- All staff receive training on identifying and escalating potential conflicts
- Annual review and attestation of compliance with this policy
- Conflicts Register
Falcon maintains a Conflicts of Interest Register documenting:
- All identified conflicts (actual, potential, and perceived)
- The assessment of each conflict
- The measures taken to manage or mitigate each conflict
- Any disclosures made to investors
The register is reviewed at least annually and updated whenever new conflicts are identified.
- Disclosure to Investors
Where a conflict cannot be adequately managed through organisational arrangements, we will disclose the nature of the conflict to affected investors before undertaking the relevant business.
Disclosure is a last resort, not a substitute for effective conflict management.
- Your Rights
If you believe a conflict of interest has not been adequately managed or disclosed, you may:
- Raise the matter with Karl Finance at info@karl.finance
- Escalate to Falcon Investment Management Ltd’s Compliance Officer at compliance@falconcapital.co.uk
- If unresolved, eligible complainants may refer the matter to the Financial Ombudsman Service
- Review
This policy is reviewed at least annually, or more frequently if there are material changes to our business or regulatory requirements.
- Contact Us
If you have any questions about this policy, please contact:
Karl Finance LLP
Email: info@karl.finance
Falcon Investment Management Ltd
Email: compliance@falconcapital.co.uk