Actis is regulated by the UK FCA and is required to have measures in place to identify and manage any conflicts of interest. The first stage of any conflict management plan is an internal legal review and referral to the CIO who determines appropriate measures to manage the conflict. These may include:
- establishment of an information barrier between teams representing different funds or Pools;
- independent valuations of affected assets; and/or
- establishment of transaction specific investment committees.
Following a decision by the CIO, a recommended conflict management plan will be implemented by Actis. The plan, and adherence to it, will be reported to the Investment Committee, who will take into account the effectiveness of these conflict management measures in deciding whether or not to proceed with the relevant investment. Where a conflict cannot be managed or resolved to the satisfaction of both Actis and the relevant Investor Panel, Actis will not proceed with the investment.
Additional conflicts can arise with regards to an individual’s personal interests. Actis has rules regarding personal holdings of shares in investee companies or in companies in which Actis has considered investing. All employees complete a Compliance Declaration and abide by the Compliance Manual.