Conflicts of Interest Policy
1. Purpose and scope
This policy sets out how Burlingame identifies, manages and discloses conflicts of interest. It applies to Burlingame, its principals (currently Daniel Sharp), any staff, contractors and advisory panel participants, and their associates (relatives and entities they control or benefit from). Daniel Sharp is Burlingame's compliance officer.
2. Approach
We avoid conflicts we cannot manage, control those we can, and disclose all of them. Disclosure alone is not enough for a material conflict.
3. Principal co-investment
- Principals invest through the same vehicle, in the same class, at the same price and on the same fees, carry, costs, information and exit terms as investors. No side letters or rebates.
- Principal commitments are disclosed in the deal note, with any change notified before close.
- Principals do not sell, transfer or hedge their interest ahead of investors.
- If no principal can invest in a deal, it is not offered.
4. Allocations
- The allocation method is set before a deal opens and stated in the deal note.
- Related parties (principals' associates, staff, advisors, referrers) receive no priority or different terms.
- In an oversubscribed deal, principal commitments are scaled back at least pro rata with investors.
- Allocation decisions are recorded with reasons.
5. Fees and third party benefits
- Burlingame does not accept fees from sellers in secondary transactions we bring to investors, unless disclosed before investors commit.
- Gifts or entertainment above A$200 from deal counterparties are recorded. Cash is never accepted.
6. Outside roles and relationships
Outside roles held by principals are disclosed and approved. Holdings in, board or advisory roles with, and personal relationships with a deal company, manager or seller are disclosed in the deal note.
7. Personal trading
- Principals and associates obtain clearance before dealing personally in any company, fund or vehicle Burlingame is reviewing, has offered, or has declined in the last 12 months, or in related listed securities.
- No trading on inside information, no front running a Burlingame deal, and no personal investment outside the deal vehicle in an opportunity that came to Burlingame without clearance.
- Principals declare relevant holdings annually.
8. Register, breaches and review
All conflicts are recorded in a conflicts register, reviewed quarterly and before each deal opens, and kept for at least seven years. This policy is reviewed annually.
Material conflicts are also reported to our Australian financial services licensee.