Our commitment

The value of our advice depends on trust that it is objective and free from undisclosed interests. This policy sets out how SUR+ identifies, discloses, and manages conflicts of interest. It applies to all partners, employees, and experts acting on behalf of SUR+.

What a conflict of interest is

A conflict of interest arises when the interests of SUR+, the personal interests of our people, or the interests of another client could affect, or appear to affect, the objectivity of the advice we give a client. Examples include:

  • Advising two or more clients whose interests conflict on the same matter.
  • One of our people having a financial interest, position, or family relationship connected to a client or to a party affected by an engagement.
  • An engagement involving an institution where one of our people previously served.
  • Accepting gifts, fees, or other benefits that could influence professional judgement.

Identification before an engagement

Before accepting an engagement, we check for potential conflicts against existing clients, ongoing engagements, and the personal interests of the people who will be involved. The check is repeated if the scope of an engagement changes materially.

Disclosure and management

Where a potential conflict is identified, we will take one or more of the following steps:

  • Disclose it to the client in writing and proceed only with the client’s consent.
  • Assign a separate team and keep information separated between teams.
  • Ask the person concerned to step away from the engagement.
  • Decline or end the engagement if the conflict cannot be adequately managed.

Former public officials

Some of our partners previously held positions at the central bank and other public institutions. They remain bound by the confidentiality obligations and post-employment rules that apply to former officials. SUR+ does not use, seek, or offer non-public information from any institution. Our advice is based on analysis of public information and professional experience.

Confidentiality

Client information is used only for the engagement concerned and is not shared with other clients or third parties without consent, unless required by law.

Personal interests, gifts, and hospitality

  • Our people must disclose relevant personal interests, including positions outside SUR+ and financial holdings connected to a client.
  • Our people must not trade financial instruments on the basis of information obtained from client engagements.
  • Gifts and hospitality may only be given or accepted when they are reasonable in value, infrequent, and not intended to influence a decision. Anything given to public officials is restricted in line with applicable anti-corruption and gratification rules.

Review and reporting

This policy is reviewed periodically by SUR+ leadership. Clients or others with concerns about a potential conflict of interest may contact us in confidence.

Contact: hello@surplusadvisory.id.