Conflicts of Interest
Identification, disclosure, and management of actual and potential conflicts.
Effective: January 1, 2026 · Reviewed annually by the Chief Compliance Officer
The Aukeo Conflicts of Interest Policy establishes the standards by which actual and potential conflicts — between the firm and its LPs, between LPs across funds, and between the firm and its personnel — are identified, disclosed, and managed. The policy is administered by Compliance and overseen by the Audit Committee.
Cross-fund conflicts
Investment opportunities eligible for more than one Aukeo fund are allocated under a written cross-fund allocation policy. Allocations are documented at Investment Committee and reported to affected LP Advisory Committees.
Related-party transactions
Transactions with related parties are prohibited without prior LP Advisory Committee consent, documented arm's-length pricing, and independent third-party review where material.
Personnel conflicts
Outside business activities, board seats, and material investments by firm personnel require written pre-clearance by Compliance and are subject to annual reconfirmation.
Questions regarding this policy may be directed to the Chief Compliance Officer at [email protected].