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Appian Holdings

PRI reporting framework 2017

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage (Not Completed)

SG 02. Publicly available RI policy or guidance documents (Not Completed)

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

The Investment Advisor to the Fund, ACAL, is authorised and regulated by the Financial Conduct Authority. As such, when sourcing investment opportunities for Appian's consideration, ACAL must adhere to the following ethical standards in relation to conflicts of interest:

1. All conflicts of interest must be managed appropriately

2. All staff should be sensitive to the potential and actual conflicts of interest in the areas they work

3. Any conflicts of interest much be disclosed to the Compliance Officer, who maintains a register of conflicts and their appropriate management

4. It is unacceptable to ignore conflicts of interest

All staff receive induction/ annual refresher training on conflicts of interest issues and management, and must sign confirmations that they have received the training, together with their adherence to all standards of the Compliance Manuals which cover the rules and behaviour for the following topics:

1. Conflicts of interest

2. Confidentiality

3. Insider trading

4. Personal account dealing

5. Gifts

6. Anti-money laundering/anti-corruption

In addition, the Fund governing documents themselves set out the procedures and rules for managing conflicts of interest, in particular through its Investor Advisory Committee whose function is to consider and consult on actual and potential conflicts of interest.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)