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PM Capital

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. 組織として、投資プロセスにおける潜在的な利益相反を管理するポリシーを策定しているかどうかについて明示して下さい。

03.2. 投資プロセスにおける潜在的な利益相反を管理するポリシーについて説明してください。

PM CAPITAL maintains a Conflicts of Interest & Related Party Policy.

Our policy requires investments to be managed in a manner necessary to promote the interests, objectives and strategies of the investment portfolio. The Company will comply with the Execution and Trade Allocation Policy.

In summary, the Company will consider any actual, apparent or potential related party and conflict of interest issues in its management of the portfolio’s assets, particularly where an entity related or associated within the PM CAPITAL Group is involved.

  • always act in the best interests of the party it is representing
  • where participating in an arrangement in more than one capacity, it must fulfil each of its roles diligently and with due care;
  • agreement setting out the terms of the arrangement provides capacity for any potential conflict of interest arising to be dealt with and a process stipulated for the arbitration
  • where a transaction involves a trade of an asset from one portfolio/fund to another the transaction must be conducted either:
    • on market; or
    • on a demonstrable arms-length basis and in the best interest of each portfolio/fund with supporting documentation
  • transaction should be disclosed to Scheme members as soon as reasonably practicable, Compliance Committee notified.


03.3. 補足情報。 [任意]

The 3 mechanisms that PM CAPITAL will use to manage conflicts of interest will involve one or a combination of the following:
1. controlling conflicts of interest

  • Identifying - report the actual, apparent or potential conflict of interest to the Compliance Officer in the first instance.
  • assess and evaluate - determine in each case if the conflict:
    • 1. can be controlled; and
    • 2. should be disclosed; or
    • 3. should be avoided.
  • Implement an appropriate response:
    • disclose conflict;
    • provide an alternative source of service to a client or member;
    • initiate internal disciplinary action; or
    • take any other action the Compliance Officer, CEO, or the Board, considers appropriate
  • Monitoring Conflicts Management
    • Compliance Officer will maintain a Conflict of Interest register
    • Compliance Measures - keep compliance monitoring records
    • Records - at least 7 year

2. avoiding conflicts of interest; and

3. disclosing conflicts of interest.


PM CAPITAL has a reputation for encouraging good ESG practices and we regularly engage the management of the companies that we own around the continuous improvement of ESG practices.
Failing a suitable outcome, we are happy to approach the boards of listed companies directly, as well as taking our case to the press.
We will generally oppose proposals where we see:
§The election of inappropriate directors, particularly where there is not a majority of independent directors or where there has been excessive turnover of board / senior executives
§Excessive management remuneration arrangements, or a lack of alignment between executive incentive structures and a company’s operating performance
§The appointment of auditors who are not independent.
Agitating for change in this way helps us to unlock the inherent value in a company in order to achieve a better outcome for our investors.
One example involved Austar which, as part of their Employee Share Plan, provided $43 million in interest-free loans to 13 senior managers and an $8.2 million interest-free loan to their chief executive.
As a minority shareholder, we were unable to block the employee share plan and so raised our concerns with management. We then voiced our views in the press to ensure that the new Employee Share Plan had more appropriate incentives in place.

SG 04. Identifying incidents occurring within portfolios (Private)