Conflicts of Interest Policy
At Nexus Arb, we are committed to managing conflicts of interest with the same precision and integrity we bring to every investment decision. We believe trust is earned not only through performance, but also through transparency in how we operate and make decisions on behalf of our capital partners.
Our Policy
Our firm does not operate multiple funds or pooled vehicles with competing objectives. Every investment we pursue is offered on identical terms to all participating clients, with full principal co-investment from our own balance sheet. Nevertheless, we recognize that certain situations, such as sourcing, structuring, or allocating opportunities, may give rise to potential conflicts of interest. This policy outlines how we identify, monitor, and manage such situations to ensure fair and equitable treatment for all clients.
Governance & Oversight
Conflicts of interest are overseen directly by the firm' s leadership. Any proposed transaction that could present a material conflict undergoes review by a designated conflicts committee, which includes non-deal team partners to ensure independent oversight.
Types of Potential Conflicts
- Allocation of investment capacity in limited-access opportunities
- Principal transactions where the firm or its affiliates are counterparties
- Secondary market trades involving client-to-client transfers
- Situations where voting rights could impact the economic interest of clients differently
Management Methods
- Identical Terms: All clients receive the same economic terms, no preferential fees, liquidity, or access.
- No Cross-Client Trades: We do not execute transactions between client accounts.
- Clear Disclosure: We provide clients with advance notice and transparent documentation when a material conflict is identified.
- Internal Segregation: Information barriers exist between deal origination and portfolio oversight functions where needed.
- Opt-Out Rights: Clients may decline participation in any investment if a potential conflict is disclosed.
Information Handling
Client information is never shared externally for marketing, cross-selling, or any non-operational purpose. We do not share data with other clients, affiliated entities, or counterparties unless explicitly required to complete a transaction. However, to fulfill operational, regulatory, or legal obligations, limited client information may be disclosed to essential third-party service providers, such as transfer agents, clearing houses, custodians, escrow banks, or settlement intermediaries, strictly for the purpose of executing transactions, holding assets, or ensuring compliance with applicable laws. In rare cases, client information may also be disclosed when required by law, including under court order, warrant, subpoena, or official regulatory investigation. In all cases, information is shared on a need-to-know basis and subject to strict confidentiality and data protection standards.
Continuous Improvement
We periodically review and refine our conflict management framework to ensure it evolves alongside our investment strategies and regulatory landscape. Feedback from capital partners and regulatory reviews inform ongoing enhancements.
Contact Information
For questions or concerns regarding our conflict of interest policy, please contact our compliance team at:
compliance@nexus-arb.com