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Albright Capital Management LP

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.

As a registered investment adviser, ACM has adopted a Conflicts of Interest Policy that sets forth policies and procedures to implement ACM’s legal and ethical requirements as a fiduciary for its investment advisory clients. ACM's policy identifies various circumstances that could potentially be deemed a conflict of interest, and provides for associated procedures intended to address the conflict of interest in a manner that is fair and equitable for ACM and its clients while ensuring that clients are not disadvantaged relative to ACM, including the disclosure of the same to its clients.  Most of these are disclosed and agreed with investors in ACM's funds at the time of investment, with the balance to be disclosed and resolved with the Advisory Committee of investors in the fund if they arise.  In addition, ACM's Policy covers the following specific matters:  (1) placement agency costs, if any; (2) size of capital raise; (3) transaction fee offsets;  (4) resolution of conflicts arising from conflicting mandates; (5) investment allocations; (6) follow-on rounds; (7) co-investments; (8) fees derived by affliated parties; (8) shareholder-directorship appointments to portfolio companies (conflict in fiduciary duties); and (9) divestment timing of assets held by multiple funds of different vintages.  


03.3. Additional information. [Optional]

We would be happy to submit the Conflicts of Interest of Policy, which is too large to be included in these responses.

SG 04. Identifying incidents occurring within portfolios (Private)