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Summary of our Conflicts Management Policy


Colonial First State (“CFS”) has an established conflicts management policy that outlines its requirements regarding the identification of organisational and personal conflicts that may arise through the provision of our products and services and how they are avoided and addressed.


Our conflicts management policy is a key component of our conflicts management framework and is a primary means for communicating our approach to the management of conflicts across CFS‘s business operations in its capacity as RSE Licensee. CFS must take all reasonable steps to identify conflicts and avoid (wherever required or appropriate to do so) in accordance with the policy or otherwise prudently address actual, potential or perceived conflicts. The policy applies to CFS, its responsible persons and employees (collectively referred to as “our representatives”) and outlines how we: 

  • identify any relevant duties and relevant interests of CFS and its responsible persons;
  • identify and monitor all potential and actual conflicts;
  • avoid conflicts unless:
    • they can be addressed prudently and fairly; and
    • priority can be given to the interests of members;
  • address a conflict (in the event of a conflict arising that cannot be avoided) ensuring that the conflict is prudently addressed in accordance with the requirements of our policy, with priority given to the duties to, and interests of, beneficiaries;
  • ensure that appropriate action is taken in the event of a conflict arising, including ongoing evaluation of arrangements to ensure conflicts are addressed and escalated or alternative action taken if required; and
  • record in the minutes of relevant Board and committee meetings, details of each conflict identified and the action taken to avoid or prudently address the conflict.


Our representatives are required to be aware of circumstances that can give rise to a conflict and be able to identify when a conflict arises and disclose this information accordingly. Responsible persons are also required to disclose any relevant duties and relevant interests prior to their appointment and on an ongoing basis. Relevant duties and relevant interests of CFS as RSE Licensee and its responsible persons are recorded and maintained in the CFS RSE Licensee Register of Relevant Duties and Register of Relevant Interests. For further information and content contained in this register please refer below.

Regular reviews and enquiries are also undertaken to ensure we identify all conflicts arising from CFS’s relationship, or the relationship of a responsible person or employee, with an existing or prospective service provider, adviser or other personal or business interests, including any conflicts that have the potential to affect the service provider’s performance in respect of the obligations undertaken for CFS’s business operations.

Compliance with our conflicts management policy is monitored on an ongoing basis and the policy is reviewed periodically to ensure it remains adequate and operating effectively.

Acknowledgements: APRA Superannuation Prudential Standard SPS521, APRA Superannuation Practice Guide SPG 521.

RSE Licensee Register of Relevant Duties and Register of Relevant Interests

To assist in the identification and management of potential and actual conflicts, CFS maintains an RSE Licensee Register of Relevant Duties and Register of Relevant Interests. The registers contain up-to-date information of any Relevant Duties and Relevant Interests that apply to Avanteos Investments Limited as RSE Licensee under CFS, and its Responsible Persons.