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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.

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.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within portfolio companies.

04.2. Describe your process on managing incidents

          Actis RI team works closely alongside the investment teams to identify and manage incidents that occur. There are four primary mechanisms:

1. An obligation for company management to notify Actis of any material ESG incidents, and collaborate with Actis on the process of investigating, managing and preventing reoccurrence, is included in our shareholders agreements.
2. Actis investment team take seats on the board of our companies where ESG incidents, and the management of material incidents, is discussed.
3. For our higher risk investments, Actis constitutes a dedicated ESG Committee (as a sub-committee to the board) where any ESG incidents are appraised in detail and measures to manage ESG incidents are reviewed by the management team, Actis directors and the Actis RI team.
4. The Actis RI team typically work closely with company management to build ESG capacity. This often involves the recruitment of dedicated ESG professionals into the management team to identify and manage ESG risks and opportunities.