Conflicts of Interest, Gifts & Hospitality

Our approach

A conflict of interest exists where someone’s personal interests, relationships or outside activities could influence, or reasonably appear to influence, their judgement in their work for Navitra or for a client. A conflict is not in itself wrongdoing. Failing to declare one is.

This policy applies to all directors, employees, contractors, consultants, interns and agency workers of Navitra.

Types of conflict

• Financial interest: shares or a stake in a supplier, competitor or client, or a director’s interest in a contract Navitra is entering.
• Personal relationships: a close friend or family member at a client, supplier or competitor.
• Outside activities: second jobs, advisory roles, directorships or freelance work, especially in financial services or AI.
• Gifts and hospitality around a business decision.
• Information: using client or confidential information for personal benefit or another client’s benefit.
• Navitra and a client: our commercial interest conflicting with a client’s interest or its customers’.
• Client and client: serving competing lenders where confidential information or a model built for one could benefit another.

Keeping clients separate

Each client’s data, configurations and client-specific fine-tuned models are kept logically separated. A model fine-tuned on one client’s data is used only for that client, and staff working on one client’s deployment must not share its confidential information with another client.

Declaring and managing conflicts

1. Declare in writing before taking part in the related decision, and in any case within 5 working days of becoming aware; on joining; and in an annual declaration, even if there is nothing to declare.
2. Record in the Conflicts of Interest Register.
3. Assess whether it could affect Navitra’s decisions, a client or a client’s customers.
4. Manage through removal from the decision, independent review, information barriers, disclosure to the client, or giving up the interest. Where a conflict cannot be managed, Navitra declines or withdraws from the activity.
5. Review open conflicts at least annually.

Directors also declare interests in proposed transactions as required by sections 175 to 177 of the Companies Act 2006, and the declaration is minuted. Where a conflict affects a client and cannot be fully managed, we disclose it to the client clearly and in good time.

Gifts, entertainment and hospitality

• Up to £50 per person per occasion: may be accepted or offered without recording (except for Public Officials).
• £50 to £150: recorded in the Gifts & Hospitality Register within 5 working days.
• Over £150, or more than three occasions from the same party in 12 months: approved in advance and recorded.
• Any value to a Public Official: written approval in advance and recorded.
• Never acceptable: cash or cash equivalents; anything during a live tender, negotiation or renewal; anything given in return for a business decision; hospitality where the host is not present; travel or accommodation paid by a client or supplier without advance approval.

Inside information and market abuse

Navitra does not trade in financial instruments, but client work can expose us to non-public, price-sensitive information about lenders with listed shares or bonds. We treat client information as potentially inside information, never deal in a client’s securities while holding it, never disclose it outside normal duties, and keep an insider list where a client asks us to. Suspicions of market abuse are reported immediately.

Reporting and oversight

Conflicts, gifts and hospitality, breaches and training are reported to the Board at least annually. Our first report, covering 24 June 2025 to 23 October 2026, recorded no conflicts, gifts, hospitality or breaches. Concerns can be raised with the Director or through our speak-up routes. This policy works alongside our anti-bribery and corruption policy.