Abraaj takes all reasonable steps to ensure that conflicts of interest are identified, prevented or resolved. Abraaj’s Conflict of Interest Procedural Document highlights the areas that may give rise to a conflict and the mechanisms Abraaj uses to identify and mitigate them (including staff declarations of external business interests, disclosure of personal account transactions, inside information declarations and anti-bribery and corruption programme).
Abraaj’s Counter Party Due Diligence (CPDD) process is designed to identify potential conflicts of interests and quantify and mitigate money laundering, terrorist financing, sanctions risk and other regulatory risks surrounding its investment activities. The CPDD process is designed to enable Investment Teams to verify the identity of the counterparty, its legal and beneficial ownership, funding sources, key designated individuals and any relationships between the counterparty and Abraaj which may give rise to a conflict of interest.
After an investment has been made, Partner Companies are required to sign a management representation letter. The letter includes reporting requirements relating to conflicts of interest. The letter should be completed by the company’s management and shared with their boards on a bi-annual basis. Investment Teams should review the board minutes to ensure discussion about the letter is appropriate and complete.