Northmill’s Management Process for Conflicts of Interest

The following stages are a summarized description of Northmill’s established process for management of conflicts of interest.

1. Identifying of circumstances, potential new conflicts of interest or re-evaluation of previously identified conflicts of interest, due to information or events from external sources (for example external auditor or Finansinspektionen) or internal sources (for example employees or financial reports). This also applies to changes in the business or structure of the consolidated situation to which Northmill belongs.
2. Reporting of identified circumstances (conflict of interest) to the Chief Executive Officer.
3. The Chief Executive Officer is responsible for registering incoming reported circumstances in a log of conflicts of interest. Furthermore, the Chief Executive Officer shall assess whether the reported circumstance is a potential or actual conflict of interest and how the circumstance should be handled, in consultation with the Compliance Function if necessary. The completed assessment of the handling thereof will be documented.
4. All Northmill’s identified potential conflicts of interest are documented and will be reviewed at least annually. The review should consider the incoming identified conflicts of interest that are documented by the Chief Executive Officer in the log of conflicts of interest.

The Chief Executive Officer shall appoint a responsible manager to ensure that each identified conflict of interest will be appropriately managed. The Compliance Function is responsible for the monitoring of the identified conflicts of interest and regular reporting to the Board of Directors.

Northmill shall inform customers any conflicts of interest which have been identified and may adversely affect customers well in advance of an agreement or as soon as Northmill assesses that despite the measures taken will not be able to counteract the conflict of interest.


Page last updated: 2020-09-11