Other potential conflicts of interest
1) Potential conflict : Investments carried out by Access Capital Partners, their Directors, advisors and employees.
Procedure : Access does not invest for its own account in Access’ Funds - nor does it invest in any other funds aside from money market funds. In addition, the Code of Ethics provides that Access Directors and employees are prohibited from investing for their own account into any of the portfolio funds, any listed companies, or any other fund of funds. More generally, all transactions in which a staff member would have a distinct advantage because of their function at Access are prohibition.
Controls and formalization: All staff must declare their personal accounts upon hire, and notify Access of any changes. Upon hire, all staff must read and sign the Code of Ethics. Signed copies are held by the Risk Management and Compliance Director.
2) Potential conflict : Investments by a fund or mandate advised or managed by Access into another product advised or managed by Access.
Procedure : Generally speaking, investing in other Access funds is not permitted under the funds’ investment policy.
3) Potential conflict : Confidential information pertaining to portfolio companies acquired by Access.
Procedure : As provided in the Code of Ethics, Directors and staff of Access must at all times ensure the strict confidentiality of any restricted information provided by holdings or target holdings. Should any Director or employee find himself in possession of confidential information, he may not use it for any purpose other than the one for which he initially acquired such information. He must also refrain from sharing this information with any other Access Director or employee without advising him of its confidential nature.
Controls and formalization: Annual certification by employees of adherence to Code of Ethics.
4) Potential conflict : Remuneration; gifts and entertainments; outside business activities.
Procedure : Access’ remuneration policy follows the professional rules incorporated in the AIFM Directive (and relevant national laws as applicable). Any new or existing outside business activities or remuneration must be disclosed and are subject to approval by the Board, as provided for in the Code of Ethics. Any pre-existing ties with a holding or target holding by a Director of employee that would impair his or her capacity to make independent decisions must be disclosed to the Board. Directors and employees may generally not accept any remuneration, gifts or entertainment of any form in the course of their duties. Gifts which cannot be refused must be declared in writing to the Compliance Officer.
Controls and formalization: Required disclosures and approvals; annual certification by employees of adherence to Code of Ethics; list of all outside business activities of staff.
5) Potential conflict : Selection of counterparties and service providers.
Procedure : Selection of service providers and counterparties is carried out via an independent process based on predetermined, objective criteria. See specific procedure. Counterparties and service providers will be re-assessed annually.
Controls and formalization: Initial and ongoing due diligence.