Conflicts of interest are not an abstract governance concept. They are real, structural forces that shape decisions, incentives and outcomes. More than a decade ago, Dean Wetton Advisory (DWA) articulated this truth in a presentation that drew on one of the most powerful governance case studies of our time: NASA’s Challenger and Columbia inquiries. Those investigations revealed how misaligned incentives, opaque reporting lines and compromised independence can lead to catastrophic outcomes. The lesson was simple but profound: transparency exposes reality and independence protects it.
Well before stewardship became a mainstream industry focus, DWA adopted this principle as the foundation of its advisory model. DWA’s early governance framework emphasised three core ideas: expose conflicts, align interests and remove vested pressures. In its presentation, DWA referenced Richard Feynman’s insistence that “nature cannot be fooled,” a reminder that governance failures are rarely about technical errors. They are about cultural ones. That philosophy shaped DWA’s DNA from the outset.
Over the years, this early thinking evolved into a structured, embedded conflict management system that now underpins every part of our business. The most significant development has been our move to employee ownership, which removes the traditional principal–agent problem entirely. At DWA, those who advise clients are also accountable for the long term success of the firm. There are no external shareholders, no product lines to promote and no incentive to recommend complexity or activity based solutions. This governance structure ensures that advice is driven solely by what is best for each scheme and its members.
Our conflict of interest policy is reviewed annually and is designed with one purpose: to protect client interests through transparency and independence. It sets out how conflicts are identified, disclosed and managed, and it is applied consistently across procurement, manager research and reporting. Potential conflicts are highlighted upfront in proposals, reports and direct communication. This includes situations where we advise asset managers, where we support procurement exercises or where our research intersects with providers we have previously engaged. Every instance is logged in a formal conflict register, available for client review.
The evolution of our approach is also reflected in our stewardship practices. In our 2026 Stewardship Code Report, we describe how independence is not simply a structural feature. It is a cultural one. Our peer review process ensures that every piece of advice is challenged by a suitably qualified colleague, reducing the risk of bias or oversight. Our fee philosophy reinforces this independence: we avoid activity based fee structures that reward complexity and instead favour models that reflect value delivered. This alignment of interest is central to our governance ethos.
Transparency also extends to how we work with managers. We do not sell products and we do not receive commissions or trails. When we assess managers, we use our own ESG and climate scoring system, developed to reflect intention, stewardship and engagement rather than marketing labels. Where we identify gaps or concerns, we engage directly with managers and record the outcomes. This ensures that our recommendations are based on evidence, not relationships.
Our conflict management approach has also adapted to the changing regulatory landscape. As stewardship expectations have grown, so has the need for clear reporting. We support clients in compiling implementation statements, documenting voting activity, significant votes and any issues encountered with managers. Where data is missing or inconsistent, we challenge managers and disclose the issue transparently. This reinforces our commitment to accuracy, independence and accountability.
The continuity between DWA’s early governance lessons and our modern practice is intentional. The principles that shaped our thinking more than a decade ago — transparency, independence, alignment — remain the foundation of our approach today. What has changed is the sophistication of the systems that support them. Employee ownership, peer review, conflict logs, transparent procurement protocols, ESG scoring frameworks and stewardship reporting have transformed a philosophy into a fully embedded governance model.
Conflicts of interest will always exist. What matters is how they are surfaced, understood and managed. At DWA, we believe that good governance requires transparency and transparency requires independence. By actively exposing conflicts rather than avoiding them, we ensure clients receive advice that is unbiased, aligned and fully focused on their members’ best interests.
For further guidance or to explore how this applies to your scheme, contact us on +44 20 3422 5000 or enquiries@deanwettonadvisory.com.