Conflict of Interest Statement & Policy

Stray Partners AS
Last Updated: 25.07.2025

1. Purpose

This policy outlines Stray Partners’ approach to identifying, disclosing, and managing conflicts of interest. Our goal is to ensure that all business decisions and recommendations are made impartially, free from external influence or personal gain, and in the best interests of our clients, stakeholders, and the integrity of our operations.

2. Scope

This policy applies to:

  • All employees, board members, subcontractors, and consultants engaged by Stray Partners

  • All decision-making, analysis, advisory work, or procurement conducted under the Stray Partners name

  • All client, partner, and supplier interactions where independence, fairness, or confidentiality could be compromised

3. Core Statement

Stray Partners AS is an independent, objective, and neutral organization. We serve what is correct and right, without secondary motives or interests. All advice, analysis, and decisions are based solely on evidence, data, and ethical principles.

We do not allow any situation - personal, financial, relational, or professional - to influence our work in ways that could impair objectivity or harm trust.

4. What Constitutes a Conflict of Interest

A conflict of interest may arise when a person’s private interests - family, friendships, financial, or social factors - could interfere with their ability to act in the best interest of Stray Partners or its clients.

Examples include (but are not limited to):

  • Recommending a service provider where the decision-maker has a personal or financial stake

  • Receiving gifts, favors, or commissions from vendors or clients

  • Working on a project where a close relative is a stakeholder

  • Using confidential information gained through Stray Partners for personal benefit

  • Participating in decisions that benefit one’s own external business activities

5. Disclosure and Management

All individuals covered by this policy are required to:

  • Proactively disclose any actual, potential, or perceived conflicts of interest to their manager or designated compliance lead

  • Refrain from participating in related decision-making until the matter is assessed and resolved

  • Document disclosures using the internal Conflict of Interest Declaration Form when required

Where a conflict is identified:

  • Mitigating actions may be taken, including recusal, reassignment, or added oversight

  • In serious or unresolved cases, disciplinary measures may apply

6. Gifts, Hospitality & Services

Employees and representatives of Stray Partners must avoid accepting gifts, entertainment, or hospitality that could improperly influence business decisions or create the appearance of bias.

Participation in conferences, events, or professional gatherings is permitted when it serves a legitimate business or learning purpose. Modest hospitality - such as meals, refreshments, or standard accommodation - may be accepted when:

  • It is appropriate and customary in the context of the event

  • It is not excessive in value

  • It does not create a sense of obligation or preferential treatment

  • It is transparently registered in the Hospitality & Gift Log

Transparency & Registration

All gifts, hospitality, and services provided, including accommodation, meals, event invitations, and other benefits, must be recorded in the Stray Partners Hospitality & Gift Log, regardless of value. This ensures transparency and enables internal review and accountability.

Managers are responsible for reviewing entries to ensure offerings do not compromise objectivity or create conflicts of interest.

7. Confidentiality

All conflict of interest disclosures are treated as confidential and handled sensitively. Disclosure is encouraged and does not in itself constitute misconduct. However, failure to disclose a relevant conflict may result in disciplinary action.

8. Review and Governance

This policy is reviewed periodically or upon changes in laws, business operations, or organizational structure. It forms part of Stray Partners’ broader governance framework, including our:

  • Code of Conduct

  • Anti-Bribery and Corruption Statement

  • ESG & Sustainability Policy

  • Data Protection Policy

Approved by: Adrian Stray CEO, Stray Partners AS 25.07.2025