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Conflicts of Interest

In its delegated regulation (EU) no. 231/2013 stipulates that an AIF manager must have internal rules that describes how the company handles conflicts of interest.

The guidelines for conflicts of interest shall identify the circumstances that constitute or may give rise to a conflict of interest that entails a significant risk that the interests of fund shareholders or other clients will be adversely affected and specify the procedures to be followed and the measures to be taken to deal with such conflicts

AIF managers with a license for discretionary portfolio management must, in accordance with Section 2 of the Act (2013: 561) on Managers of Alternative Investment Funds (“LAIF”), Chapter 8 Section 12 and Chapter 9 Section 9 of the Securities Market Act (2007: 528) (“LV”):


Establish and implement effective organizational and administrative procedures so that all reasonable measures are taken to prevent customers' interests from being adversely affected by conflicts of interest; and take all reasonable steps to identify, prevent and manage the conflicts of interest that may arise between the institution and a client or between clients in connection with the provision of investment services and ancillary services, including those caused by compensation or benefits received from others than the client, the institutions own compensation system or other incentive structures.


Nyhavn has on this basis adopted policies and procedures for identifying, reporting, managing, and preventing conflicts of interests. For information on the policy, please contact

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