Conflict of Interest Policy

J M Surette Advisors
Last Updated: 05. 29. 2024

Purpose

The purpose of this Conflict of Interest Policy is to protect the integrity of JM Surette Advisors (the "Company") and the trust of our multiple clients and partners. This policy outlines the procedures for identifying, disclosing, and managing actual, potential, and perceived conflicts of interest, particularly in relation to maintaining confidentiality and impartiality among different clients.

Definition of Conflict of Interest

A conflict of interest arises when the interests of JM Surette Advisors, including those of its clients, interfere, or appear to interfere, with the Company’s ability to provide unbiased and confidential advisory services to its clients.

Scope

This policy applies to all contractual engagements, activities, and relationships involving JM Surette Advisors and its clients.

Identifying Conflicts of Interest

Potential conflicts of interest may include, but are not limited to:

• Engaging with multiple clients within the same industry or sector where interests may conflict, such as competing healthcare systems.

• Sharing or using confidential information obtained from one client for the benefit of another client.

• Any financial, personal, or professional interests that might influence, or be perceived to influence, the performance of duties for JM Surette Advisors' clients.

Disclosure of Conflicts of Interest

Initial Disclosure: At the start of any contractual engagement, JM Surette Advisors will disclose any potential conflicts of interest to the client, especially if engagements with direct competitors are anticipated.

Ongoing Disclosure: JM Surette Advisors will promptly disclose any new potential conflicts of interest as they arise during the course of the engagement.

Annual Disclosure: JM Surette Advisors will complete an annual conflict of interest disclosure to ensure ongoing compliance across all contractual engagements.

Managing Conflicts of Interest

Upon identification of a potential conflict of interest, the following steps will be taken:

Assessment: The relevant parties within JM Surette Advisors will assess the potential conflict to determine its nature and extent.

Mitigation Plan: If a conflict is determined to exist, a mitigation plan will be developed, which may include:

• Maintaining strict confidentiality protocols to ensure no sharing of sensitive information between competing clients.

• Recusal from engagements or tasks that might lead to a conflict.

• Offering the client the option to terminate or alter the engagement terms to resolve the conflict.

Documentation: All disclosed conflicts and the corresponding mitigation plans will be documented and retained for record-keeping and compliance purposes.

Enforcement

Non-compliance with this policy may result in the termination of the contractual engagement with JM Surette Advisors. The Company reserves the right to take appropriate measures to address any violations of this policy.

Confidentiality

All disclosures and discussions related to conflicts of interest will be treated with the highest level of confidentiality, consistent with the need to assess and manage the conflict.

Review and Revision

This policy will be reviewed annually and updated as necessary to ensure it remains effective and in line with regulatory requirements and best practices.

Contact Information

For questions or further guidance on the Conflict of Interest Policy, please contact Jahn Marie Surette directly.

This Conflict of Interest Policy is intended to uphold the highest standards of integrity and professionalism at JM Surette Advisors. By adhering to this policy, we ensure the trust and confidence of our clients, partners, and stakeholders.