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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

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.4. Indicate what norms you have used to develop your investment policy that covers your responsible investment approach.

other (1) description

          United Nations-backed Principles for Responsible Investment.
        

other (2) description

          The Investment Advisor is authorised and regulated by the Financial Conduct Authority and adheres to the highest governance and ethical standards when sourcing investment opportunities.
        

01.6. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

Appian regards social, environmental and governance standards as key to its success and is committed to working to ensure that it and the companies that it invests in meet international best standards and practices.

A significant part of Appian's due diligence process in relation to a potential portfolio company will focus on Environmental, Social and Governance ("ESG") issues relevant to that particular company, including in relation to its geographical location and local community. No two investments are the same, therefore the ESG matters to perform due diligence on will differ from target company to target company. If environmental, social or governance issues are identified during the due diligence phase that do not have appropriate / achievable risk management procedures in place in order to satisfactorily address and improve these matters, that acquisition would not proceed to completion as Appian would decline the investment.

There are no variations or exceptions to Appian's investment policies with regard to ESG matters, and these investment policies are rigorously applied across all investment due diligences.


SG 02. Publicly available RI policy or guidance documents

New selection options have been added to this indicator. Please review your prefilled responses carefully.

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

URL/Attachment

02.4. Additional information [Optional].


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)


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