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Markham Rae (Delisted)

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

          The HFSB Standards; The ILPA Private Equity Principles
        

other (2) description

          The International Financial Reporting Standards; The UK Financial Reporting Council’s Stewardship Code
        

other (3) description

          The FCA Principles for Approved Persons
        

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]

     


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.

Independence of decision making

It is conceivable that Markham Rae could be unduly influenced by the interests of a client. Therefore, our policy is to avoid influence on our decision making by having a robust corporate governance infrastructure, in which clients are neither represented or have a casting vote on committees. Our independence of decision making is further supported by a Fair Allocation policy and a formal Investment Approach.

Personal Interests

To manage potential conflicts associated with outside business interests, we require staff to declare personal interests and to disregard the interest when acting on behalf of clients.

Personal dealing

Staff are required to comply with our Personal Account Dealing Policy, which amongst other things requires staff to obtain Compliance approval before dealing.

Gifts

Staff are required to comply with our Gift and Entertainment policy, which amongst other things states that gifts cannot be given or accepted, unless it can be demonstrated that no conflict of interest is created by doing so.

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Private)


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